Ethical Guidelines

The Maxell Group is aware that the electrical machinery, electronic and telecommunications equipment and information industry, of which it is a part, helps to support the global economy and the international community. In order to merit the confidence of society and to help establish a mode of corporate conduct that will contribute to the building of a truly rich and vital society, the Maxell Group hereby establishes the following corporate ethical guidelines.

(1) We will strive to identify the needs of society, develop products, software and services beneficial to society and provide our customers with the best possible quality at an acceptable price.

(2) We will give due consideration to safety in the development, design, manufacture and supply of our products, software and services.

(3) We will work constantly to develop new products and technology. We will respect intellectual property rights such as technical information, patents and trade secrets, and will supply outstanding products, software and services to our customers, based on new technology.

(4) We will foster the creativity and self-esteem of employees and cultivate a corporate climate in which the individual is free to express his or her opinion. This will allow us to sustain our capability to develop new technology and products.

(5) In developing and supplying useful products, software and services, with due attention to safety, we must address not only the needs of local communities but also those of the international community. With this in mind, we will ensure compliance with the laws and regulations of the countries with which we have business dealings, and strive to deepen our understanding of various societies and cultures.

(1) We will ensure that we elicit ethical behavior in the business environment to fit our mission to contribute to society.
In accordance with the principle of self-accountability that is the basic premise of a market driven economy, we will engage in fair, transparent and free competition in a spirit of self-help and self-sufficiency. In this regard, we will ensure that our activities conform to high ethical standards, complying not only with the law but also with social norms.

(2) We will establish systems to ensure compliance with anti-trust law and/or other related laws and regulations, and will not engage in illegal behavior, the pursuit of profit by illicit means or activities that are in contrast with international norms.

(3) To eradicate any conduct that could be interpreted as mutual dependence or "adhesion" to political or administrative bodies, we must first eliminate any notion of reliance on such bodies and must then work to build transparent relationships. It is through diligent efforts of this kind that we will be able to establish sound and ethical relations with the government sector.

(4) Our purchasing transactions will generally be open to all suppliers. We will conduct such transactions in a fair and transparent manner and according to easily understandable procedures. In the course of purchasing transactions, we will select products, software and services according to economically rational criteria, consistent with these ethical guidelines. We will require our suppliers and manufacturing contractors to adhere to the relevant laws and conform to the Code of Conduct and ethical standards of the Maxell Group.

(5) Systems and practices that have been in place for some time will be reviewed continually to ensure that they are fair and transparent, and conform to international norms.

(1) We will communicate with society and ensure that our activities are compatible with social norms in a fair and transparent way. This will be accomplished through timely and appropriate disclosure of the kind of information, which is required by society, in every area of corporate management, through positive public relations programs, and other appropriate methods of communication.

(2) We place importance on promoting understanding of corporate management and activities among shareholders and investors through disclosure and other investor relations (IR) activities.

(3) We recognize the importance of communication with local communities and will actively engage with them in both dialogue and local community activities.

(4) We will strictly control not only internal information of which creation, maintenance and/or storage is required under legislation such as the corporate law, and the financial instruments and exchange law, but also personal information such as customer information, recognizing that it is an important business asset. Such information will be used only for its intended purpose and we will not allow its misuse. In ensuring non-violation of unfair competition prevention laws or insider trading regulations, we will exercise appropriate internal controls over the acquisition, use and/or disclosure of confidential company information.

(5) We will supply appropriate corporate information in formats compatible with advanced information technology to as many in the public as possible and in an effective and efficient manner, through the use of multimedia networks and systems.

(1) Protecting the global environment is one of the most important
issues facing humanity. We will systematically pursue environmental preservation activities under the basic philosophy of working in harmony with the environment and the slogan "Conservation of the global environment for the next generation".

(2) We will maintain environmental management systems that
conform to the ISO 14001 standards and pursue resource and energy savings, the development of environmental technology, production activities, product development and supply, and collaboration with local communities through integration of the following three themes: (1) supplying environmentally friendly products; (2) pursuing environmentally friendly production activities and (3) working for peaceful co-existence with society.

(3) With regard to development and supply in particular, we will
comply with the environmentally friendly Green Procurement program, from the raw materials procurement stage onwards, ensuring strict control of chemical substances, and supplying products with a low environmental impact.

Through our officers, employees and our corporate activities, we will maintain relations with local communities. Since we are part of society and our business activities should be of benefit to society, we will engage in a variety of corporate citizenship activities. We will also establish internal conditions that make it easy for employees to engage in a range of volunteer activities on an individual and spontaneous basis.

(1) Our policy is to assure sound employment and working conditions. We will treat employees in accordance with the applicable laws and regulations in each country or region. We will assure introduction of personnel systems and employment conditions that meet the increasing standards of living and quality of life of employees and that reflect the growing diversity of the labor force and individual lifestyles.

(2) Our policy is to provide workplace conditions which are safe and comfortable, assuring the health and safety of our employees, which is vital to the pursuit of our business activities. Besides complying with health and safety legislation in each country and region, we aim to enhance our control of health and safety issues by creating our own standards where necessary.

(3) Respect for human rights and fair and equal treatment of employees is of the utmost importance. In line with international standards such as the United Nations "Universal Declaration of Human Rights", and the "Fundamental Conventions on Human Rights" of the ILO, we will adhere to the basic principles of assuring equality of opportunity in employment, prohibiting forced labor and child labor, observing sound employment and labor practices, and providing a healthy, safe and efficient workplace environment, free from discrimination based upon on grounds of race, religion, color, country of origin, age, gender, handicap, or any other grounds that have no bearing on the business interests of the Maxell Group.

(4) We recognize that a corporate climate which encourages employees to exercise their independence, creativity and skills to the maximum, will contribute to the growth and development of the Maxell Group. We will introduce transparent, impartial, fair, and reasonable labor systems, and pursue a variety of employee development programs respecting the individuality of our employees.

(1) With the scope of corporate activities growing ever broader, and competition intensifying, we must take care not to become involved with anti-social elements or organizations. We recognize that in addition to ensuring that our own conduct is correct, it is also our duty to deal with anti-social elements and/or organizations which may be involved in dubious activities in a resolute manner, and that doing so is vital for the sound development of our corporate activities.

(2) When dealing with anti-social elements and/or organizations which may be involved in dubious activities, we will at all times maintain a sense of urgency and ensure that the way we do business offers no opportunities for them. We will comply with any applicable legislation and act in a firm and resolute manner, in the belief that we should not be intimidated, make payments or take advantage of such elements.

The Maxell Group does business on a global scale. Our products are both manufactured and sold throughout the world. It is therefore vital that we take a global perspective in conducting our business. With peaceful coexistence and mutual prosperity in mind, we will contribute to the communities where we do business, not only through business activities, but also by encouraging our employees to participate in voluntary activities in local communities.

We recognize that providing entertainment or making gifts the value of which exceeds social norms in the course of business, or accepting such entertainment or gifts, may severely impair the fairness and transparency of our business activities, and will not give or accept such entertainment or gifts under any circumstances. Even when the entertainment or gift is the minimum required by social convention, at all times we must adhere to the spirit of these Ethical Guidelines and take particular care to avoid any situation that is likely to be interpreted as constituting a fraudulent transaction or a conflict of corporate and personal interests. Cases in which it is difficult to determine the proper course of action should be referred to a supervisor in charge of ethical guidelines in the company.

(1) In the course of its corporate management duties, senior management will observe the following requirements and, recognizing that a corporation is a public entity, will strictly avoid conflicts of corporate and personal interests:

(a) Senior management will strive to identify the needs of society and ensure that the Maxell Group's conduct is in harmony with those needs.

(b) Senior management will be responsible for enhancing awareness and observance of the spirit of these Ethical Guidelines both within their own company and other related Maxell Group companies as well. They will also, in recognition of corporate social responsibility, perform periodic reviews of the Maxell Group’s conduct for continual improvement.

(c) Through employee education and training, senior management will work to enhance awareness of the company's role in society.

(d) Senior management will strive to establish a corporate climate and systems that are conducive to internal communication. They will work to enhance understanding between senior management and employees.

(e) Senior management will establish internal systems to encourage employees to act in the spirit of these Ethical Guidelines.

(2) Should a situation arise in which the company's social responsibility is called into question, senior management will themselves provide a clear explanation to the public of the causes and development of the situation, the proposed response and measures to prevent its reoccurrence. Having ascertained the particulars of the matter, they will deal with those involved, including themselves, strictly and speedily, and will resolve the situation in a manner that is acceptable to society.