In October 2005, Toho Chemical Industry Co., Ltd., and its affiliated companies (Toho Chemical Industry group) prepared the code of conduct materializing requests from society and the things they have kept in mind in conducting business activities.
They also made and distributed cards enabling employees to carry the code of conduct at all times so that all employees could share the spirit of the code of conduct and try to penetrate and comply with the code of conduct through in-house education and discussions within the workplaces.Additionally, we determined the resolution on “the basic policy for building the internal control system” at the board of directorsʼ meeting in May 2006 to show the conditions of construction of internal control and the stance to future efforts.

Going forward, we hope that, amid seeking the significant theme of building the internal controlsystem, we will meet the expectations of society and all parties related to the Toho ChemicalIndustry group by trying to share the spirit of the code of conduct, make arrangements for compliance, and make business operations more efficient and effective.

We sincerely comply with rules, including the related laws and regulations and internal rules by being conscious of an employee of Toho Chemical Industry and its affiliated companies while acting as follows with a sense of social responsibility:

1.Offering safe and high quality products
We offer products and technologies “relieving, satisfying, and trusted by” customers, based on the technology and creativity we have developed for many years.
2.Fair competition
We engage in fair, transparent, and free competition and do not perform actions violating the Antitrust Act, such as seeking profits by unfair and undue methods.
3.Moderate entertainment and gifts
We do not offer nor receive extravagant entertainment and gifts. We also do not attempt to bribe public servants.
4.Information management
We adequately manage the confidential and personal information of companies and customers obtained during the course of business in the office, as well as after retirement, and do not use the information for unfair purposes at all. We also do not disclose and leak the information to persons except the persons concerned without permission.
5.Disclosure of company information
We timely perform an adequate information disclosure to shareholders, investors, and customers to have them accurately understand our business conditions.
6.Prevention of insider trading
We do not make illicit transactions in shares using nonpublic information about our company and trading partners obtained during the course of business. We also do not provide third parties with nonpublic information.
7.Efforts for environmental problems
We understand that environmental protection is an important task. Complying with laws and regulations on environmental conservation and ISO 14001, we actively tackle effective utilization of resources, energy-saving, constraint of wastes, recycling, and adequate disposal.
8.Safety of workplaces
We try to prevent industrial accidents by being continuously aware of building a workplace where we can work with appropriate security. We make a report immediately and take the best safety measures when a defect or disorder is identified in the manufacturing equipment and facilities
9.Respect for the human rights
We try to build an environment of easy-to-work-in workplaces with mutual trust and good sense where there is no discrimination, sexual or power harassment, or annoyances.
10.Exhibition of personality, ability, and willingness
We are conscious of building workplaces where characteristics are developed for each employee and his or her ability is exhibited to the maximum.
11.Communication with the local community
We understand that companies cannot evolve without living together with the local community, and we seek to evolve together through communication with the local community.
12.Fighting anti-social forces
We take a firm attitude toward anti-social forces threatening the social order and sound activities of companies and never accede to fraudulent demands.
13.Management at overseas countries and territories where we operate a business
We try to comply with local laws and regulations and understand local customs and culture. We also seek to realize coexistence with local companies in mutual prosperity by promoting personnel exchanges.
In preparing such a code of conduct, the manager, as well as officers and executives, become well aware of their roles, realizing the spirit of the code of conduct and actively set the pace and make all persons concerned aware of the code. If a case violating the code occurred, the manager would internally and externally solve the problem, try to investigate the causes, and prevent a recurrence. Additionally, we internally and externally disclose the information immediately and appropriately as part of corporate accountability while inflicting impartial punishments on the persons concerned, including the manager.