We are expected to not only observe laws and rules but also to apply our own high ethical standards of sincerity and social responsibility in conducting our corporate activities. We have here made and clarified Code of Conduct, which every one of us must practice in all situations in this constantly changing management environment. We establish the following Code of Conduct and practice it sincerely, fully aware of our social responsibility. We will review and improve the contents of this Code of Conduct continually.

• 1.Our Attitude in Business
• 2.Relations with Society
• 3.Relation between Personnel and Workplace
• 4.Management of Company Assets and Information
• 5.Report/consultation system
• 6.Scope of Application and System for Promotion
• • HRS Group Basic Policy on Antisocial Forces
  • HRS Group Privacy Policy
  • HRS Group Safety and Health Policy
  • HRS Group Basic Policy on Anti-Bribery
  • HRS Group Basic Policy on Labor Management
  • HRS Group Basic Policy for Information Security
  • HRS Group Responsible Minerals Procurement Policy
  • HRS Group Basic Policy for Corporate Ethics Management

We will observe the laws of the various countries and districts in which we operate, international rules and company rules, and we will act sincerely in accordance with social norms and corporate ethics in conducting our business activity. We will not act against the interest of the company, and we will refrain from illegal and false reporting in business.

We will endeavor to develop products, which will satisfy customers, always considering the customers’ needs first. We will provide timely information on products and services, and we will try to respond sincerely to inquiries.

We will take full care for the safety and quality of the products and services that we sell and offer. In the event that damage caused by our products or services to the customer is found or a serious quality problem occurs, we will confirm the facts and report promptly and accurately to the appropriate parties both inside and outside of our company and take adequate action, such as investigating the cause of the damage or quality concern.

Fair sales activity

We will conduct our transactions sincerely in accordance with applicable laws and agreements practicing a fair and equal attitude toward customers, distributors and other business partners in our sales activity.

Prohibition of competition restrictive activity

We will not restrict free competition among our business colleagues, such as by consulting and fixing price and volume of products with them. We will not set successful bidder or the highest bid price and we will refrain from bid rigging.

Prohibition of dictating resale prices and unfairly restricting sales activity

We will not unfairly restrict the business activity of distributors, such as dictating the distributors’ price to customers and retailers or prohibiting the handling of other companies’ products.

Fair advertisement activity

We will not convey or express information in our advertisement activity that is false or might lead to a misunderstanding regarding the quality, performance and/or the specification of our products and services.

Fair transaction

We will conduct transactions sincerely in accordance with applicable laws and agreements practicing a fair and equal attitude toward suppliers and consignees whom we will select in accordance with appropriate selection standards.

Prohibition of abuse of a superior position

We will not take advantage of our superior position, and we will refrain from setting unfair conditions of transactions or unfairly delaying payment.

We will conduct all financial and accounting records and reports on company management accurately and fairly in accordance with applicable laws and rules.

We will disclose information stipulated by laws and rules, as well as other information that we consider fit for disclosure, accurately and fairly in accordance with appropriate procedures in order to gain the trust of the public.

We will not sell or buy stocks of Hirose Electric Co., Ltd. And its business customers when we obtain important insider information on Hirose Electric Co., Ltd. And listed business customers until such information is publicly announced. Also, we will not make information available to employees who do not have a need to know or to third parties (customers, family, friends, or any others).

We will carefully observe the following points when importing or exporting goods, techniques and services: the existence of regulations on export for international peace and safety maintenance in related countries and regions and also, the possibility that the product or service could be converted into weapons development through its usage, user, or other transaction. We will observe applicable laws and company rules for export and take necessary precautions.

Act with moderation

We will act moderately within sound commerce customs and common sense concerning the acceptance of entertainment and gifts from business partners.

Prohibition of bribery

We will not entertain or offer gifts or special treatment that might be construed as bribery or illegal payoff for unjust business profit to public servants such as members of the Diet or heads and officials of governmental offices and foreign officials.

We will contribute to society through our personal and material assets, as well as by interacting actively with the communities in which we operate. In foreign countries, we will respect the culture and customs of that country, and we will contribute to the development of its communities. We will also try to contribute to society in our daily life.

We will conduct our corporate business under our “Basic Principle on the Environment” and endeavor to respect the environment and biodiversity conservation through reducing the use of pollutants and preventing pollution and promoting the effective use of resources and energy conservation, in compliance with environmental laws and rules.

In accordance with our “Basic Policy on Antisocial Forces”, we will take a firm attitude and actions toward antisocial groups and organizations. We will have no relation with antisocial groups whatsoever and will not take any measure that will assist them.

Respect for human dignity

We will respect basic human rights and human dignity in every aspect of our business activities. We will strictly avoid harassment, contempt, verbal abuse, unjust compelling, and taking advantage of our business and transactional position.

Prohibition of child labor and forced labor

The company will provide fair work opportunities and will strictly prohibit child labor and forced labor in any form.

Prohibit of discrimination

We will not discriminate based on sex, age, nationality, race, color of skin, ideology, social position, religion, lineage, property, disability, or political ideas.

Prohibit of inhumane treatment

We will not allow sexual harassment, including sexual statements or actions by those taking advantage of their work position against the will of the other party or parties.

Sincere efforts for solving the problems

The company will, in light of the laws and labor customs of the various countries and districts, sincerely engage with employees and endeavor to solve the problems by gaining a better understanding of each other through faithful dialogue.

We will respect privacy and will not abuse it. We will observe applicable laws and company rules including “Privacy Policy” on personal information and will prevent the disclosure and abuse of personal information.

We will strive to develop working conditions, focusing on mental and physical health and safety, in accordance with applicable laws and company rules including “Safety and Health Policy” on working safety and health. We will also implement accident prevention and emergency management procedures.

We will manage and keep company information and assets (tangible or intangible, such as brand) appropriately, and we will not grant access by others to company information or indulge in private use.

We will manage appropriately all administrative, management, technical and manufacturing secrets of our company and other companies obtained through business, in accordance with personal information regulation and company regulation, and we will endeavor to prevent the disclosure, abuse and unjust use of confidential information.
Disclosure of confidential information to a third party or its illegal use will be prohibited even after retirement.

We will keep, maintain and use our intellectual property obtained through technical developments, such as know-how, appropriately and protect them from third-party infringements. We will respect third-party intellectual property and will not knowingly infringe or use third-party intellectual property.

If we determine that there is or may be a violation of laws or company rules, etc., we will report problems that can be resolved at work to our boss, cannot solve problems at work, and report problems to the whistleblowing desk. As soon as possible, please contact your manager or immediately report to the whistle-blowing contact if it is difficult to solve the problem at work.
In this case, the content of the report and the fact of the report will be treated as confidential and the reporter will not be disadvantaged at all. We also accept anonymous reports.

When performing business, I always act by considering whether my behavior violates this norm, whether it does not exist, and how the behavior looks like from the eyes of others, and I am skeptical. If you are uncertain about a decision, do not make your own decision and always consult or consult with your supervisor or related departments for advice.

This Code of Conduct shall apply to all officers and employees of Hirose Electric Co., Ltd. And its subsidiaries.
Any subject company shall make this Code of Conduct known to its all officers and employees and provide necessary education for them to understand this Code of Conduct and act in accordance therewith.
Each overseas subsidiary may change a part of wording in this Code of Conduct depending on the laws, business practices, labor practices, and values of the country and district, however, shall not make any change of the content that is contrary thereto.

The group president of the Administration Group of Hirose Electric Co., Ltd. shall be appointed as the overall responsible person in charge of management and implementation of this Code of Conduct. The General Affairs & Legal Department shall assist the overall responsible person as the head office to promote and support the management and implementation of this Code of Conduct.
Each subsidiary’s responsible person shall cooperate with the head office for promotion.

HRS Group will establish and comply with the following basic policy for the purpose of preventing damage caused by groups or individuals that exploit violence, power and fraudulent measures to pursue economic benefits (so-called antisocial forces).

1. We will not have any relationship with antisocial forces.
2. We will work organizationally and properly to prevent damage caused by antisocial forces in cooperation with external professional institutions including police and lawyers.
3. We will reject any and all unreasonable demands from antisocial forces and take a legislative response in a firm attitude.
4. We will provide no funding to and take no backdoor trade with antisocial forces.
5. We will deal with unreasonable demands from antisocial forces as an entire organization. We will ensure the safety of officers and employees dealing with such demands.

HRS Group will recognize the importance of personal information protection and endeavor to protect personal information in accordance with the following policy.

1. We will acquire personal information needed by lawful and fair means, identifying the purpose of use to the greatest extent possible.
2. We will use personal information within the scope of the purpose of use, which is identified at the time of acquisition, and only to the extent necessary for our business.
3. We will not provide personal information to any third party without obtaining the prior consent of the subject person, except as specified in laws and regulations. In the event that we share personal information with any third party or entrust any third party with the handling of personal information, we will conduct a strict investigation of the third party and exercise an appropriate supervision over the third party to maintain the confidentiality.
4. We will assign a chief administrator in charge of the handling of personal information for the proper management to prevent illegal access to, and loss, damage, falsification or leakage of personal information.
5. We will acknowledge that the person has the right to make a request for disclosure, correction, suspension of use, or elimination of their personal information. We will promptly respond to such request to a reasonable extent.
6. We will comply with applicable laws and rules for personal information and, when appropriate, review our efforts in the above items for improvement.

HRS Group will recognize that to ensure working safety and health of employees is an important management issue. We will work together to develop safe and comfortable working conditions and strive to prevent all accidents and diseases.

1. We will reduce dangerous risks in workplaces to prevent industrial accidents by identifying the danger or harm, arising from business activities, with respect to working safety and health.
2. We will actively support the maintenance and promotion of employees’ health.
3. We will comply with laws concerning working safety and health or the orders based thereon and company rules of working safety and health.
4. We will provide continuous employee education concerning working safety and health so that employees may ensure working safety and health by understanding the importance thereof.
5. We will work together to promote working safety and health activities via smooth communication between employees and the company with respect to working safety and health.

HRS Group has established the following basic policy and will endeavor to ensure that officers and employees of the Group comply with as such.

We will not engage in any act of bribery, such as offering, promising to offer or giving, whether directly or indirectly, money, gifts, entertainment or other benefits for the purpose of obtaining or maintaining business or commercial advantages.

Likewise, we will not engage in acts of bribery to civil servants of any country and those similar thereto (e.g., officers and employees of governments, local governments, government-owned corporations, government-owned hospitals, political parties, international organizations; “Civil Servants”) for the afore-mentioned purpose. For the purpose hereof, giving of benefits includes facilitation payments. We will also comply with the applicable laws of the relevant countries in implementing this policy.

We will ensure that acts of bribery to the afore-mentioned Civil Servants will not be committed through third parties such as agencies, suppliers, consultants or intermediaries.

In performing business activities, we will not accept entertainment, gifts and the like that deviate from sound business practice and/or social common sense, or that have not been approved by an authority specified by the Company.

We will keep financial, accounting and other records relating to operations of the Company in an accurate and appropriate manner in order to demonstrate compliance with anti-bribery laws and regulations of the relevant countries and this Basic Policy.

We will promptly report to the relevant personnel any suspected breach by an officer or employee of the Group of anti-bribery laws and regulations and/or this Basic Policy so that we can deal with it in a timely manner.

We will explain the purposes of this Basic Policy to our customers and suppliers to obtain understanding thereof and endeavor not to cause doubt about transactions in the entire Group.

< Supplementary note >
Facilitation Payments
In some countries and regions, Civil Servants may request a payment of a small amount in terms of customs, inspections, immigration, application for issuance or extension of visas, or installation of water and sewage or telephone services without legal basis. Such payment is called a facilitation payment. This facilitation payment is seen as a bribe to Civil Servants and as such is prohibited in some countries and regions.
However, in the event where a payment of money or other material benefits is necessary to avoid putting an individuals’ life, body or freedom at risk (violence, threat, arrest, imprisonment, etc.), their safety is given top priority, and such payment shall not be regarded as a bribe.

HRS Group has established the following basic policy regarding social responsibilities and working conditions and will comply in such a manner as to respect fundamental human rights and individual dignity and achieve labor management compliant with applicable laws and regulations of the relevant countries.

• The Company will not allow any child under 15 years of age to work in any manner, and will take remedial action for children.
• The Company will not allow young workers over 15 and under 18 years of age to work for more than eight hours a day.
  Further, the Company will not allow young workers to work at night.
• The Company will not expose either children or young workers to any situation, in or outside of the workplace, that is hazardous or unsafe to their physical or mental health and development.

• The Company will not engage in the use of forced or compulsory labor in any manner.
• The Company will not retain original identification papers and will not require employees to pay employers’ agents or sub-agents’ recruitment fees, other related fees and deposits to the Company upon commencing employment.
• The Company will not withhold any part of any employee’s salary, benefits, property or documents in order to force such employee to continue working for the Company.
• Employees will have the right to leave the workplace premises after completing the standard workday.
• Employees will be free to terminate their employment upon request to the Company in accordance with the Work Rules.
• The Company will not engage in or support human trafficking.

• The Company will not engage in or support discrimination in hiring, remuneration, access to training, promotion, termination or retirement based on race, national or social origin, caste, birth, religion, disability, gender, sexual orientation, family responsibilities, marital status, political opinions, age or any other condition that could give rise to discrimination.
• The Company will not interfere with the exercise of employees’ rights to observe tenets or practices, or to meet needs relating to race, national or social origin, religion, disability, gender, sexual orientation, family responsibilities, or political opinions, etc.
• The Company will not allow any behavior that is threatening, abusive, exploitive or sexually coercive, including gestures, language and physical contact, in the workplace or facilities provided by the Company.
• The Company will not subject employees to pregnancy or virginity tests under any circumstances.

• The Company will treat all employees with dignity and respect.
• The Company will not engage in or tolerate the use of corporal punishment, mental or physical coercion and/or verbal abuse of employees.
• The Company will not treat employees harshly or inhumanely.

• The Company will comply with applicable laws and regulations regarding working hours and holidays.
• Employees will be granted at least one day off per week.
• The Company will ensure that overtime work must be performed under the agreement with employees.

• The Company will always pay to employees statutory or industry minimum wages or more as remuneration.
• The Company will not make deductions from wages for disciplinary purposes.
• The Company will ensure that the composition of employee wages and benefits are detailed clearly and regularly in writing for each remuneration period.
• The Company will comply with all applicable laws and regulations with respect to wages and allowances, and pay remuneration in a method convenient to the employee in cash, via bank transfer or otherwise.
• The Company will pay for all overtime at a premium rate as defined by the relevant local law.
• The Company will not use labor-only contracting arrangements, consecutive short-term contracts and/or false apprenticeship to avoid meeting its obligations to personnel under applicable laws and regulations pertaining to labor and social security.

• In recruitment activities, the Company will not request applicants to submit photographs of their faces along with their curricula vitae or any other documents of any kind.
• At the time of concluding an employment agreement with employees, the Company will disclose to employees the contents of the agreement as well as any and all Company regulations having relevance to the agreement.

• All employees will have the right to form, join and organize trade union(s) of their own choice and to bargain collectively on their behalf with the Company.

1.Policy

• The Company will define in writing, in the workers’ native language, this Policy.
• The Company will review this Policy regularly in order to continually improve, taking into consideration changes in applicable laws and regulations, its own code of conduct requirements and any other company requirements.
• This Policy will be documented, implemented, maintained, communicated and made available in a comprehensible form to all employees.

2.Management Review

• The Company will periodically review the adequacy, suitability, and continuing effectiveness of its policies, procedures and performance results.Where appropriate, system amendments and improvements will be implemented.

3.Implementation and Verification

• The Company will provide periodic instruction and awareness programs about the Policy so that all employees can understand and implement this Policy.
• The Company will continuously monitor the afore-mentioned efforts and the results thereof to verify the validity of the management system.

• The Company will request suppliers to comply with this Policy.
• The Company will use reasonable efforts to regularly ensure that suppliers meet the requirements under this Policy.

• The overall person in charge of managing and promoting this Policy shall be the group president of the Administration Group, Hirose Electric Co., Ltd., who will promote this Policy in collaboration with relevant responsible persons at subsidiaries and the head office.

The Hirose Electric Group (the “HRS Group”) recognizes the importance of information security in carrying out its business, and strives to ensure information security by setting out the following basic policy for information security in order to protect information and information systems (“Information Assets”) in a safe and appropriate manner.

All important Information Assets possessed by the HRS Group shall be evaluated and grouped into categories according to their importance, and after risks relevant to individual Information Assets are clarified, necessary protective measures for Information Assets shall be taken to prevent information leakage, alteration and destruction by fire, intrusion into information systems by outside parties, and other incidents.

The officers and employees of the HRS Group shall comply with laws and regulations of each country, along with contractual obligations and other rules concerning information security.

The officers and employees of the HRS Group shall receive education on information security regularly so that they will become more aware of the importance of protection of Information Assets and their roles and responsibilities for information security.

In the event that a security incident has, or may have, occurred, the HRS Group shall endeavor to promptly take necessary responses and procedures.

Responsible Minerals Procurement Policy

The HRS Group promotes "Responsible Minerals Procurement" to fulfill our social responsibility in supply chain. The HRS Group procures the minerals without involvement in conflicts, human rights violation or labor issues.
The HRS Group requests suppliers to understand the HRS's procurement policy and cooperate with us in the survey on the procurement process. Furthermore, the HRS Group requests suppliers to procure minerals from the refiners/smelters approved by globally recognized frameworks such as RMI (Responsible Minerals Initiative).

Activities

1. We establish management system of minerals procurement that complies with OECD Due Diligence Guidance.
2. We promote "Responsible Minerals Procurement" throughout the supply chain in collaboration.
3. We identify and evaluate supply-chain risks by using globally standardized programs such as the latest CMRT.
4. When problematic mineral procurement is found, we immediately take corrective action.
5. We disclose results of mineral procurement survey upon customers' request.

The HRS Group has established and will comply with basic policies for ensuring that its employees will comply with national and regional laws and regulations as well as international and in-house rules and they will act honestly in compliance with social norms and corporate ethics.

(1) Fair sales activities and promotional/advertising activities

1. Fair sales activities
   The Company requires employees to conduct transactions sincerely in accordance with applicable laws and agreements practicing a fair and equal attitude toward our customers, distributors and other business partners at all times in our sales activities.
2. Prohibition of competition restrictive activities
   The Company prohibits employees from getting involved in any act that may lead to the restriction of free competition such as consulting and fixing prices and/or volume of products with business colleagues. Further, with regard to bidding activities, the Company prohibits bid rigging such as illegal agreements to fix a successful bidder or the highest bid price.
3. Prohibition of dictating resale prices and unfairly restricting sales activities
   The Company prohibits employees from unfairly restricting the business activities of distributors, such as dictating the distributors’ price to customers and retailers or prohibiting them from dealing in products of other companies.
4. Fair promotional/advertising activities
   The Company prohibits employees in their promotional/advertising activities from making false or misleading indications or expressions in connection with the quality, performance and/or specifications of our products and services.

(2) Fair Transactions with Suppliers (Vendors and Consignees)

1. Fair transactions
   The Company requires employees to select suppliers in accordance with appropriate selection standards and to conduct transactions sincerely in accordance with applicable laws and agreements practicing a fair and equal attitude toward suppliers and consignees at all times.
2. Prohibition of abuse of a superior position
   The Company prohibits employees from abusing their superior positions in ways such as setting unfair conditions of transactions with suppliers or unfairly delaying payments to them.

(3) Attitude to Entertainment and Presents

1. Act with moderation
   The Company requires employees to act moderately in compliance with sound commerce customs and common sense with regard to the acceptance of entertainment and gifts from business partners.
2. Prohibition of bribery
   In accordance with the “HRS Group Basic Policy on Anti-Bribery”, the Company will not entertain or offer gifts or special treatment that might be construed as bribery or illegal payoffs for unjust business profit to members of the Diet and heads and officials of the national government and municipal offices as well as to officials of governments and municipal offices of other countries.

(4) Management of Company Assets and Proprietary Information and Their Adequate Use

The Company requires employees to manage and keep in an appropriate manner any proprietary information and tangible or intangible assets (including brands) of the Company, and prohibits employees from accessing any information of other persons or companies without authorization or use for a personal purpose.

(5) Confidentiality

Employees will be required to manage all administrative, management, technical and manufacturing secrets of the Company and other companies that may be obtained through business appropriately in accordance with applicable laws and in-house regulations and to take care to prevent the disclosure, abuse or unauthorized use of such information.
Employees will be prohibited from disclosing this confidential information to any third party or using this confidential information in an illegal manner even after their retirement

(6) Protection of Intellectual Property

Employees will be required to keep and manage in an appropriate manner intellectual properties of the Company including know-how that they may obtain through technical development activities, to protect them from third-party infringement and to utilize them in an active manner.
Employees will be required to respect third-party intellectual properties and will be prohibited from intentional infringement on or unauthorized use of any intellectual property of any third party.

(7) Responsible minerals procurement

The company will work to procure minerals that are not involved in conflicts, human rights violations, labor issues, etc. based on the "Responsible Minerals Procurement Policy."
We request our suppliers to conduct a mineral procurement route survey and request procurement from an internationally recognized smelter.

(1) Policy

• The Company will provide this Policy in writing to employees in accordance with their native languages.
• The Company will review this Policy at regular intervals in order to keep updating the Policy taking into consideration amendments to applicable laws and regulations, revisions to its own code of conduct and any other changes.
• This Policy will be documented to be implemented, maintained and communicated and will be made accessible in a form that is understandable by all employees.

(2) Management Review

• The Company will periodically review the adequacy, suitability, and continuing effectiveness of its policies, procedures and performance results and will amend or improve its management systems as necessary.

(3) Implementation and Verification

• The Company will provide explanations about this Policy and education based on the Policy in order to ensure that the Policy is understood and complied with by all employees.
• The Company will monitor on a continuous basis the aforementioned efforts and the results of such efforts in order to verify the validity of its management systems.

• The Company will request its suppliers to comply with this Policy.
• The Company will make reasonable efforts on a regular basis to ensure suppliers are in compliance with the requirements of this Policy.

• The person in charge of the management and promotion of this Policy shall be the group president of the Administration Group, Hirose Electric Co., Ltd., who will promote this Policy in cooperation with responsible persons and offices of respective subsidiaries.