Code of Corporate Ethics

Believing that it is essential corporate behavior to ensure legal compliance and to fulfill Corporate Social Responsibility, we Sanyo Chemical Group are introducing a Code of Corporate Ethics, which will be applied to maintain sustainable society. With good sense and integrity we are committed to improving our society and are following our company motto, Let us contribute to building a better society through our corporate activities.

Based on these company business ethics, we prescribe our principles of corporate behavior as follows:

1.	We Sanyo, by the development and provision of socially beneficial goods and services, in a safe and responsible manner, shall strive to earn the confidence of our consumers and clients.

2.	We shall promote fairness, transparency, free competition and right trade. We shall also ensure to protect our own intellectual property as well as that of any third party while taking necessary measures to protect personal data and customer related information.

3.	We shall recognize that a positive involvement in environmental issues and an active effort towards accident prevention are indispensable requirements for the sustainability and activity of our business.

4.	We shall engage in active and fair disclosure of corporate information, not only to shareholders, but also to a wide range of members of society.

5.	As *good corporate citizens*, we shall actively engage in philanthropy and other activities of social benefit.

6.	We shall strive to respect the diversity and individuality of our employees, to promote safe and comfortable workplaces, and to ensure the physical and mental well being of our employees.

7.	We shall observe all laws and regulations applying to our overseas activities, respect the culture and customs of other nations and strive to manage our overseas activities in such a way as to promote and contribute to the development of local communities.

8.	We shall reject all contacts with organizations involved in activities in violation of the law or accepted standards of responsible social behavior.

All high levels of management, cooperating with other managers, must assume the responsibility for implementing this code and take all necessary action in order to promote awareness within Sanyo Chemical Group and inform the group companies and business partners of their responsibility. Management must also promote the development and implementation of systems that will contribute to the achievement of ethical corporate behavior.

In the event of any violation of these principles, members of management must investigate the cause of the violation, develop reforms to prevent its recurrence, and make information publicly available regarding the intended actions for reform. After the prompt public disclosure of appropriate information regarding the violation, responsibility for the violation and its effect should be clarified, and disciplinary action should be taken, regardless of the offending member's position in the company.

Established : April 1,2003
2nd version released : January 1,2005

Advice on Compliance

In the Code of Corporate Ethics we have declared that it is essential corporate behavior to ensure legal compliance and to fulfill our corporate social responsibility. We Sanyo Chemical Group are voluntarily adopting this advice in order to promote a sustainable society and are following our company motto, keeping in mind good sense and integrity towards the surrounding society. All company executives and employees are expected to follow this code of corporate ethics:

Therefore, we expect all of us to answer positively to each question below.

1.	Can you confirm that your judgment of compliance is not clouded by anything such as profit-making motives or budget short fall?

2.	Can you confirm that your decisions have not been founded on over-optimism or wishful thinking and thus containing legal risk?

3.	Can you confirm that your decisions comply with the code of corporate ethics and are in no way damaging to Sanyo Chemical Group corporate reputation?

4.	Can you confirm that you have not concealed information or have not made judgments that could be considered unfair or selfishly motivated?

5.	Can you confirm that you have conducted yourself in a fair and honest manner and have not engaged in illegal or legally risky actions?

6.	Can you confirm that you have not been forced to do something that you suspected it was unfair or might have been illegal?

7.	Can you declare openly that your actions have always been legal, just and fair?

If you are having difficulty in your decision making, please do not hesitate to discuss duly with your superiors or people concerned. If you feel necessary, you can also consult the compliance hotlines listed below:

Internal Hot Line: General Manager of Audit Division (Secretary of Compliance committee)

External Hot Line: The contact information is withheld.

Established: April 1, 2004