Code of Corporate Ethics

We, Sanyo Chemical Group, are maintaining our Code of Corporate Ethics, believing that it is essential corporate behavior to ensure legal compliance and to fulfill corporate social responsibility, which has been implemented to promote 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 corporate ethics, we prescribe our principles of corporate behavior as follows:

1.	We, Sanyo, shall develop and provide socially beneficial and safe products and services, and in this way earn the satisfaction and confidence of our consumers and customers.

2.	In our business activity, we shall be devoted to fair competition and appropriate transactions.

3.	We shall proactively take initiatives to conserve the environment and prevent accidents and disasters as crucial 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 widely to the public. We shall also protect our intellectual properties and respect those of others, as well as be thorough in our protection and management of personal information and customer information.

5.	As a "good corporate citizen," we shall actively engage in philanthropy and other activities of social benefit.

6.	We shall respect the diversity and individuality of our employees, and ensure their well being by providing a safe and comfortable working environment.

7.	In responding to the globalization of business activities, we shall comply with the laws and regulations of the countries and regions where we conduct business, respect human rights and other international norms, manage our operations in due consideration of various cultures and customs as well as the interests of our stakeholders, and contribute to social and economic development in those countries and regions.

8.	We shall strongly oppose and thoroughly reject all contact with antisocial forces and organizations that pose a threat to the order and security of civil society.

All management, cooperating with managerial staff, must undertake the responsibility and take all necessary actions for implementing and promoting this Code of Corporate Ethics within Sanyo Chemical Group while expecting business partners to respect it. Management must also promote the development and imple-mentation of systems that will contribute to the achievement of the Code of Corporate Ethics.

In the event of any violation of these principles, top management must investigate the cause of the violation, develop reforms to prevent its recurrence, and make information publicly available regarding the intended corrective actions. After showing accountability by making prompt and appropriate public disclosure, disciplinary action will be taken with all concerned persons including the President.

Established: April 1, 2003

2nd version revised: January 1, 2005

3rd version revised: May 26, 2008

4th version revised: April 1, 2011

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, 2003
The 2nd edition revised: January 1, 2005