Based on the spirit of the Three Corporate Principles, Mitsubishi Shoji Chemical will conduct corporate activities in accordance with the following standards.

Aim of Corporate Business Activities

Through its business activities, Mitsubishi Shoji Chemical Corporation will endeavor to increase its value. At the same time, the company will strive to enrich society in all ways, developing and offering its customers the best services and products, with the highest regard for safety.

Fitness and Integrity in Corporate Business Activities

Mitsubishi Shoji Chemical Corporation will continue to develop its business activities in compliance with all relevant laws, international regulations and internal rules. The company will act responsibly and will respect the highest social standards.

Respect for Human Rights and Employees

Mitsubishi Shoji Chemical Corporation will respect human rights and will not engage in any discrimination. The company will preserve and improve its corporate strengths through the development of its employees, all the while respecting the character and individuality of each employee.

Information Security and Disclosure

While Mitsubishi Shoji Chemical Corporation will continue to develop, implement, and improve the effectiveness of its information security management system, at the same time, the company will disclose information accurately and in a timely fashion, so as to maintain transparency and be correctly understood by both its stakeholders and the general public.

Consideration for Environmental Issues

Mitsubishi Shoji Chemical Corporation understands that an enterprise cannot continue to prosper without consideration for its environmental performance, and will strive to protect and improve the global environment and pursue sustainable development through all aspects of business activities.

Contribution to Society

As a responsible member of society, Mitsubishi Shoji Chemical Corporation will actively carry out philanthropic programs in an effort to promote the enrichment of society. Moreover, the company will support efforts of its employees to contribute to society.

Basic Policy

All officers and employees of Mitsubishi Shoji Chemical Corporation must, in accordance with the “Three Corporate Principles” and “MC Group Standards of Conduct,” comply with all the applicable laws, rules and regulations, international standards and rules, and internal corporate rules and policies when they perform their work. In addition, all officers and employees of Mitsubishi Shoji Chemical Corporation must observe proper business protocol and act in a socially responsible manner.

Compliance Acts

1. 1. Respect human rights, and do not discriminate nor engage in any form of harassment.

   1. （1）Do not discriminate on the basis of any issues such as race, color, creed, religion, gender, gender identity, sexual orientation, national or regional origin, age, or disability.
   2. （2）Do not engage in any form of harassment.
   3. （3）Understand and recognize human rights issues.
   4. （4）Respect the indigenous culture, customs, and languages in countries and regions in which we conduct business, and conduct such business operations in harmony with the local society.
   5. （5）Do not employ child labor or forced labor that could lead to the infringement of human rights. Also, make every effort to avoid taking part in the infringement of human rights in cooperation with business partners, etc.

2. 2. Ensure that our business operations are conducted in an environmentally sustainable manner, and comply with all treaties, laws, and regulations related to the environment.

   1. （1）Comply with treaties, laws, and regulations concerning the environment, and protect human health and the environment.
   2. （2）Promote sustainable development.
   3. （3）Use resources and energy efficiently, as well as reduce, use, and recycle waste effectively.

3. 3. Promote fair business practices and comply with trade rules, regulations, and internal corporate rules and policies.

   1. （1）Understand and comply with the laws and regulations which cover your commodity and service industry. Obtain the necessary permission and conduct necessary official procedures.
   2. （2）Do not participate in any concerted actions in restraint of trade, including wrongfully fixing or maintaining prices, volumes, production facilities and/or the market, or otherwise restraining competition in any particular field of trade.
   3. （3）Do not refuse transactions with any specific trader (such as discount traders) or new traders jointly with others in the same business area or through trade associations, and do not improperly consult with competitors about bids.
   4. （4）Do not conduct any business activities that would or might unfairly impair the rights of subcontractors.

4. 4. Comply with the rules and regulations of international trade.

   1. （1）Understand and comply with international trade rules and regulations.
   2. （2）Carefully evaluate whether to undertake an international transaction involving military or other similarly regulated goods or services, taking into consideration the company’s reputation, and make proper application to the relevant authorities, if required.

5. 5. Protect and properly use confidential and proprietary information of the company, and manage information obtained from outside the company and rights such as intellectual property rights of third parties.

   1. （1）Carefully manage the Company’s trade secrets, and do not disclose or use such secrets for unauthorized purposes.
   2. （2）Ensure that a proper non-disclosure or confidentiality agreement is concluded with third parties in advance if the disclosure of trade secrets to such third parties is required in the course of business transactions.
   3. （3）Do not disclose or use the Company’s trade secrets even after termination of employment.
   4. （4）Do not make public statements or announcements on behalf of the Company without proper authorization, and refer all inquiries to the responsible department (for example, if contacted by mass media regarding a matter for which a section of the General Affairs Department is responsible, you should contact that section and request them to respond.)
   5. （5）Do not infringe intellectual property rights owned by another company or person (such as an unauthorized copying of computer software).

6. 6. Do not engage in insider trading.

   1. （1）Do not sell or purchase the parent company’s securities while in possession of its “material non-public information” until such information is released publicly.
   2. （2）Do not sell or purchase any other company’s securities while in possession of its “material non-public information” until such information is released publicly.

7. 7. Do not engage in acts of misconduct such as insider trading. Avoid conflicts of interest with the Company; maintain a distinction between corporate and private business.

   1. （1）Do not use the Company’s tangible and/or intangible assets other than for authorized business purposes.
   2. （2）Do not use the Company’s assets or resources for personal gain.
   3. （3）Do not unfairly use the Company’s corporate information systems.
   4. （4）Do not work at another company while employed by the Company without the Company’s prior approval.
   5. （5）On termination of employment, return to the Company all of its assets in your possession, including but not limited to any materials or equipment, and any files and documents generated for, or in connection with, the conduct of Company business.
   6. （6）Do not conduct personal (such as political and religious) activities in the workplace (including, without limitation, assembly, speech, propaganda, solicitation, and distribution or posting of literature) having no relation to the Company business without the Company’s approval, except for personal religious activities, such as praying, socially and generally accepted to be conducted at work place in the country, if any.

8. 8. Record and report accounting and financial information timely and accurately.

   1. （1）Do not record accounting and financial information inaccurately or in a way that would mislead those who receive it.
   2. （2）Record expense and revenue timely.
   3. （3）Record credit and debt accurately.
   4. （4） Do not create off-the-book assets or liabilities.

9. 9. Observe proper legal and ethical standards with respect to gifts and entertainment within the proper limits of social convention.

   1. （1）Do not improperly provide entertainment, gifts, conveniences or other economic benefits to public officials or those in a similar position, whether at home or abroad.
   2. （2）Do not pay a fee or make a donation to an agent or consultant when it is known, or should be known, that part of such fee or donation could be used to wrongfully gain influence with public officials or those in a similar position.
   3. （3）Do not provide any gift, entertainment, or any other type of economic gain to customers, or their directors, officers, employees or other related persons, in excess of accepted business and social norms.
   4. （4）Do not receive gifts or enjoy entertainment in excess of accepted business and social norms; Obtain an approval according to internal corporate rules prior to receiving any gifts or enjoying entertainment from any organization or entity rendering services to the Company.

10. 10. Resolutely oppose any organization, group, or individual engaged in unlawful activities, and do not provide money or other type of economic benefit to such individuals.

    1. （1）Do not agree to demands for money or accept any unfair request from any organization, group or individual engaged in unlawful activities in violation of the Commercial Code, etc.
    2. （2）Be aware of and avoid contact with any organization, group or individual that is believed to be engaged in unlawful activities in violation of the Commercial Code, etc.
    3. （3）Do not become knowingly involved in or unwittingly party to acts of terrorism, drug dealings, money launderings, and other individual or organized criminal activities, and take all responsible steps to ensure that neither you nor the Company becomes involved, knowingly or unknowingly, in such activities.

11. 11. In the event of an act that violates this “Code of Conduct,” officers and employees will promptly report to and consult with either their Organization Heads, Chief Compliance Officer, Audit & Supervisory Board Member (Full time), Internal Whistleblower Desk (Compliance Office) , Compliance Hotline , MC Group Outside Legal Counsel Compliance Mail Box and Helpline , or LUKS (limited to any breach (or potential breach) of relevant antitrust law and anti-bribery law) , upon discovering or committing any violation of this “Code of Conduct,” even unintentionally.

    1. （1）Each and every officer and employee will provide all the necessary cooperation to facilitate the Company being able to ascertain the series of facts and take corrective action, including any recurrence prevention measures.
    2. （2）The Organization Heads, Chief Compliance Officer, Audit & Supervisory Board Member (Full time), or Internal Whistleblower Desk (Compliance Office) in receipt of the report or consultation will not reveal the name, etc. of the reporter or consultation seeker without his/her consent and will ensure that the reporter or consultation seeker will not receive disadvantageous treatment for his/her report or consultation.
    3. （3）In cases where the reporter or consultation seeker has received disadvantageous treatment for his/her report or consultation on a “Code of Conduct” violation, he/she will immediately notify the Chief Compliance Officer.
    4. （4）The report or consultation will be made or sought orally, by phone, letter, e-mail, or interoffice mail.