Basic Ethics and Code of Conduct

Objectives and Basic Stance

 This Compliance Policy is a summary of matters that require attention with respect to issues of particular importance to Sun* in realizing "a world where everyone is engaged in value creation. Therefore, this is not an exhaustive list. It is only a basic idea.

 The important thing is to speak up when we have questions about business practices and procedures. For example, when we encounter a problem, we should not pretend to ignore it. In the busyness of our daily work, we tend to forget to ask questions, but it is important to always review what we are doing, what we have done, and what we are going to do from the viewpoint of compliance. Leaving it to others, saying "It's none of my business, someone else will probably figure it out" or irresponsible attitude of "Business is not about fine-sounding talk, so just do as everyone else does" may make our company worse, but it will not make it better. To create a rewarding workplace where people can work with pride, let's be courageous in our efforts to practice compliance with ethics, laws, and regulations.

 We emphasize that the final decision-making criteria for ethical and legal compliance must be based on one's own conscience and character of high integrity. No compliance policy, no matter how detailed, no matter how many legal materials are distributed, can be all-inclusive or all-encompassing. In today's world of globalization, information technology, deregulation, and the need for speed in business, what is most important is the spiritual attitude of each individual to follow the tenets of the compliance policy, and the conscience that accompanies courage. Therefore, it is important to make ethical decisions based on conscience as the basis of business.

 Ethical decision-making based on conscience" here means to question the appropriateness of one's actions from the standpoint of an impartial third party, leaving aside one's own personal, workplace, or business interests. If the action is not reprehensible or acceptable in anyone's eyes, then it can be considered a good thing to do. However, if the situation seems very complicated and difficult to judge, do not hesitate to always consult with those around you or the relevant department. Also, if you believe that a company's conduct deviates, or may deviate, from the law, the Articles of Incorporation, or the Compliance Policy, you should promptly report this fact. Please be assured that we will protect your privacy with regard to your inquiries. If you have a problem, please be willing to speak up. This is the best way to make us a good place to work and to ensure that our company enjoys a high level of trust from society and the market.

 We have only one goal: to create a fair workplace and sound business relationships. We aim to build a fair workplace and sound business relationships, to contribute to the development of society through our work, and to realize "a world where everyone can be enthusiastic about value creation. Our business is based on fairness, and our mission is to enrich society.

Guidelines for Actions

• 1. Contribution to Society

  We recognize the social value of realizing "a world where people can be absorbed in value creation" with Sun* as the infrastructure, and contribute to society through sound business operations.

• 2. Fair Business

  We will do fair and transparent business with all clients and stakeholders, like the sun shining fairly around the world.

• 3. Respect for human rights and diversity

  As a global company, we respect race and diversity and foster an open corporate culture. We will not tolerate any kind of discrimination or harassment inside or outside the company.

• 4. Respect for Intellectual Property Rights

  We respect the passion for creativity that all human beings have from birth, and we do not infringe on the intellectual property rights of others arising from our creative activities.

• 5. Information Management

  Confidential information is properly managed in accordance with internal rules and client contracts, and confidentiality obligations are strictly observed. Personal information shall be managed in accordance with applicable laws and regulations and our privacy policy, and shall not be used for any purpose other than those necessary for business operations.

• 6. Compliance with Laws and Regulations

  We will conduct ethical corporate activities by correctly understanding the laws, regulations, guidelines, etc. related to our business and by complying with not only the letter of the laws and regulations but also their spirit.

• 7. Prohibition of insider trading

  Officers and employees will not engage in any insider trading that violates securities trading-related laws and regulations. In addition, when buying or selling securities, we will ensure that prior application is made in accordance with the trading rules established by the Company.

• 8. Exclusion of Antisocial Forces

  Under no circumstances shall we take a firm stand against antisocial forces and provide them with monetary or other economic benefits.

Compliance Items

（１）Contribution to Society

（２）Fair Business

To ensure fair dealings, we must be fair and transparent in our relationships with suppliers, regulatory agencies, and various other organizations and individuals with whom we come into contact in the course of our duties.

• 1. Fair Selection of Suppliers

  Executives and employees must make decisions on suppliers based on a comprehensive evaluation of quality, service, price, past performance, reliability, and other factors. For this reason, we must not accept money, goods, or entertainment from suppliers or other business partners with whom we have a direct business relationship. This distorts the proper business decisions that we would have originally made. Even if it does not, a third party may suspect that the relationship is opaque or unfair.

• 2. Prohibition of Rebate Demands, etc.

  Do not use your position to demand money, goods, or entertainment from your business partners, even if it is indirect. Such behavior may violate laws and regulations and damage business relationships based on trust. Even if an action is considered acceptable, you should refrain from doing so if it would appear unnatural to a third party. If you feel that your actions may be misleading, please refrain from doing so.

• 3. Prohibition of Excessive Gifts, Entertainment, etc.

  Officers and employees must refrain from giving gifts and entertainment that go beyond the bounds of common sense, even if they do not have a direct business relationship with the company. This is because it may have some adverse effect on future decision-making. If you unintentionally encounter a situation that could be considered problematic, you should report the fact to your immediate supervisor or the Compliance Department and receive appropriate instructions.

• 4. Subsequent Actions

  If an officer or employee unavoidably receives a gift or entertainment that is not in accordance with the Company's regulations, he or she should report the fact to his or her immediate supervisor or the Compliance Department, who will consult with him or her and take appropriate action. Appropriate measures may include, depending on the circumstances, sending the gift back at the company's expense with a polite written refusal, returning a gift of equal value at the company's expense, or removing the individual who received the benefit from working with the business partner for a certain period of time.

• 5. Dealing with Other Benefits

  In our relationships with business partners, we may be offered a variety of favors, not limited to money, goods, or entertainment. When we find ourselves in such a situation, we must first inform our immediate superiors or the Compliance Department of the fact and receive appropriate instructions.

• 6. Healthy Relationships with Public Officials

  We must take care to maintain healthy relationships with public officials and deemed public officials.

（３）Respect for human rights and diversity

We shall not tolerate discrimination in our corporate activities on the basis of race, nationality, gender, age, religion or political ideology, disability, marital status, child or child origin, sexual orientation, or gender identity, and shall provide equal opportunities to all people. We do not tolerate forced labor, human trafficking, child labor, harassment, bullying, or unfair treatment of any kind. We will comply with local laws and regulations where our employees work, strive to provide an appropriate working environment, ensure fair working conditions, and respect freedom of association and the right to collective bargaining.Respecting the diversity of our employees and fostering an open corporate culture are prerequisites for ensuring compliance. Let us create a better corporate culture through the efforts of each and every one of us.

• 1. Respect for Human Rights and Prohibition of Discrimination

  In hiring and treating employees, we must evaluate them fairly according to their work and performance. Discrimination based on gender, race, nationality, religion, ideology, physical handicap, or other personal characteristics is prohibited under any circumstances. Even if it may not be clearly discriminatory, any language or behavior that may cause discomfort must be refrained from. Jokes, etc., based on an individual's physical characteristics are also contrary to the Company's goal of creating a rewarding workplace.

• 2. Prohibition of Harassment

  The Company will make every effort to maintain an appropriate work environment in accordance with labor laws and other relevant laws and regulations. Therefore, we prohibit all forms of harassment that may deteriorate the work environment, such as using one's position or status to force asymmetrical relationships, or repeatedly engaging in behavior that may make others feel uncomfortable.

• 3. Protection of Privacy

  Personal information of executives and employees held by the Company shall be strictly controlled and shall not be used for any purpose other than the original purpose. We will not disclose such information to outside parties without the consent of the individual unless there is a court order or other legitimate reason to do so.

• 4. Elimination of Uncertain Practices

  We do not permit the offering of money or gifts from subordinates to their superiors, including mid-year gifts and year-end gifts. This is because it may shake confidence in the fairness of decisions on promotions, transfers, etc. However, we will allow such gifts for weddings, funerals, and other occasions within the scope of common sense.

（４）Respect for Intellectual Property Rights

All officers and employees shall recognize that intellectual property rights are important corporate assets, and shall endeavor to preserve and effectively utilize such rights, as well as to respect and not infringe upon the intellectual property rights of other companies.

• 1. Preservation of Intellectual Property Rights

  We must recognize that intellectual property is an important company asset, and must properly maintain, manage, and preserve it, as well as effectively utilize it.

• 2. Utilization from a Global Perspective

  We must always be aware that the Group's services are developed on a global scale, and we must actively acquire intellectual property rights such as patent rights, which are the result of advanced and creative research and development, on a global basis, to protect them from a global perspective and utilize them throughout the Group. We must also consolidate information on intellectual property rights generated by all group companies to understand and utilize intellectual property rights as a group.

• 3. Respect for Intellectual Property Rights of Other Companies

  In researching and developing new products and technologies, we must investigate whether or not we are infringing on the intellectual property rights of other companies from a global perspective and strive to avoid infringing on their rights.

• 4. Appropriate use of intellectual property rights of other companies

  We must use intellectual property rights and information of other companies that we have obtained appropriately only within the scope of possible use stipulated in the contract, and must not make unauthorized copies of software.

• 5. Prohibition of Dead Copying

  From the viewpoint of fair competition, we shall not imitate or develop other companies' products.

（５）Information management

All executives and employees shall be obligated to maintain the confidentiality of information obtained in the course of their duties. In addition, information must be handled with special care, as the loss or leakage of such information can cause significant damage to the owner of the information in question.

• 1. Duty of Confidentiality

  Protecting customer confidentiality is the most fundamental rule for executives and employees. Officers and employees must not divulge to others any information obtained through transactions with customers, even with the consent of the customer, without justifiable reasons, such as when required by law.

• 2. What to say and do in private

  Even outside of work, employees must be careful not to divulge confidential information, etc. Talking about it at a drinking party, being overheard by others, or losing a company computer that you were carrying are all considered information leaks.

• 3. Use of SNS/Internet

  In using SNS and the Internet, we must raise literacy to prevent leakage of confidential information, and prevent information leakage as a result of viruses, hijacking, etc., in addition to preventing information leakage on our own initiative.

• 4. Handling of Personal Information

  In addition to properly acquiring and managing personal information as confidential information, we must understand that various rules are stipulated by related laws and regulations, and must handle personal information appropriately in accordance with the company's privacy policy, personal information protection policy, and other relevant policies.

（６）Compliance with Laws and Regulations

In addition to customers, business partners, investors, etc., we have legal, social, and ethical responsibilities to countless other stakeholders. Among them, compliance with laws, regulations, and rules based on social consensus is the minimum responsibility to society.

• 1. Compliance with relevant business laws

  All officers and employees must correctly understand and comply with all laws, regulations, guidelines, etc. related to this business.

• 2. Compliance with Antitrust Laws

  In the conduct of their business, officers and employees shall not engage in discussions or agreements with competitors. They must also refrain from any behavior that could raise such suspicions. In addition, any conduct that may constitute abuse of a superior bargaining position or excessive interference in the selection of directors or officers is also not permitted. These actions are highly likely to violate the Antimonopoly Law.

• 3. Accounting and Tax Compliance

  We will comply with financial and accounting rules, accurately prepare forms and documents, faithfully execute budgets in accordance with established rules, and fulfill our tax obligations in accordance with the law in light of relevant laws and regulations. All concerned officers and employees are requested to faithfully perform the administrative work necessary to carry out this task. We will not engage in any conduct that could be considered tax evasion.

• 4. Reporting to Authorities and Cooperation in Investigations

  We will report to the authorities and cooperate fully with investigations in the event of any violation of laws and regulations or other socially unacceptable problems occurring within our company, or if we suspect such violations. Each and every director and employee is expected to act responsibly in accordance with this basic stance of the Company.

（７）Prohibition of Insider Trading

Insider trading is prohibited under any circumstances, as it undermines the credibility of the securities market and the credibility of the company. All officers and employees must understand the relevant laws and regulations as well as the contents of the internal rules "Regulations for Prevention of Insider Trading" and strive to prevent insider trading.

• 1. Handling of Material Facts and Undisclosed Information

  Material facts and non-public information that may affect the company's business performance and information that has not been disclosed through IR, PR, etc. must not be disclosed through SNS, the Internet, or any other means at the discretion of the individual. You must fully understand that communication to acquaintances and others may also lead to insider trading, and you must fulfill your duty of confidentiality.

• 2. Prior Application to Buy or Sell Company Stock

  Before buying or selling shares of Sun* stock, you must follow the company's pre-application procedures. Failure to comply with the prescribed procedures may result in penalties.

（８）Exclusion of Antisocial Forces

In order to fulfill our social responsibility and public mission, and to become a more trusted company, all officers and employees must be aware of the need to block transactions with antisocial forces and ensure that no benefits are provided to them.

• 1. Anti-Social Forces Check

  The Corporate Management Division shall always conduct an investigation of new business partners, new shareholders, new hires, new directors, etc. by searching for articles on the Internet, etc. (hereinafter referred to as "Anti-Social Forces Check") in advance.

• 2. Response to Anti-Social Forces

  If a business partner or other related party is suspected of being an antisocial force, the company shall not take action on its own, but shall respond appropriately in accordance with the "Antisocial Forces Policy" and the "Antisocial Forces Response Manual". If you feel suspicious, consult with your superior first.

December 3, 2018 Enacted
Revised January 20, 2021
Revised June 21, 2023