Compliance Manual(Basic Policy・Performance Standard)

The management philosophy of T-NET JAPAN Co,. Ltd is “As a total engineering company, aims to develop wide-ranged technologies to global market, and contribute to the development of new Japan.” In order to create a pleasant and prosperous life to the employees who are capable to technology and related profession, and their families; and thus to the district community; T-NET JAPAN endeavors to contribute to the wide-ranged local and global communities.
In this compliance manual, T-NET JAPAN is responsible to company basic mission and social responsibility; in response to employees and the district communities’ entrustment and mandate. Therefore establishes a strong reliability with the guideline of “Compliance Basic Policy”, and the concrete performance guideline of the policy is “Compliance Performance Standard”.

Establish Date: March 2003
English Version: July 2016

Compliance Basic Policy

  1. Community Relationship

    Obtain good understanding of company’s basic mission and social responsibility; observe laws and regulations as well as social rules; maintain high corporate and employee ethics; act in compliance with social norms and responsibility as a corporate citizen; and execute a sound and appropriate business operation.

  2. Customer Relationship

    Provide high quality total engineering services and products; perform the role in perfection for the stable corporate management and business base enhancement; contribute to the development of employees and district communities.

  3. Business Partner・Competitor Relationship

    Create and implement an appropriate business relationship with a fair, transparent and open competition environment.

  4. Share Holder・Investor Relationship

    In order to let the public gain deeper understanding of the company, be active to publish the operation information justly and timely.

  5. Aim to Better Corporate Culture

    Create a corporate culture with the understanding of the importance of real transparent operation, together with achieving good communication internally.

Compliance Performance Standard

1. Community Relationship

(1)

Social Contribution

In harmony with the local community and global society as good corporate citizens; build the relations of trust with stakeholders to ensure sustainable improvement of corporate value; promote active social contribution with the aim of achieving the local community and global society that are prosperous and comfortable to live in; and strive to create the sustainable society.

(2)

Observe Related Regulation and Enforce Corporate Ethics

Not only have accurate understanding and observance of corporate and operation related regulations, and enforce the corporate ethics by prohibiting the acts which violate the general social norms.

(3)

Exclusion of the Antisocial Force (Triads)

Resolutely decline to deal with the antisocial forces (triads) which cause menaces to the social order and security, and exclude it determinedly without having to resort to financial solution easily.
Never do any transaction with antisocial forces and business partners related to antisocial forces.

(4)

Government Offices and Public Servants Relationship

Never offer money to public servants and deemed public servants, entertain them, make gift-giving to them, provide them with other economic benefits, and conduct any acts that may lead to misunderstanding.

(5)

Environmental Protection and Conservation

Always with good understanding of the importance of environmental protection; comply with environment-related laws and regulations and other rules; each of us acts with roots in the environment friendliness; and be active in carrying out initiatives for environmental conservation.

2. Customer Relationship

(1)

Provide High Quality Total Engineering Services and Products

Provide high quality total engineering services and products, and contribute to the community development.

(2)

Pursue Customer Satisfaction

Always grasp the customer’s needs precisely, and be minded to provide the most desirable services and solutions to customer.

(3)

Proper Management of Customer Information

Do not use customer information for the purposes other than normal operation necessity, and implement serious and proper information management.

3. Business Partner・Competitor Relationship

(1)

Otain a Fair, Transparent and Open Market Competition

1) Always do an appropriate business under the environment of fair, transparent and open market competition.
2) Do not arrange selling price with our peers and do not assign the volume, sales territories or customers.
3) Do not engage in bid-rigging in bidding such as arranging a successful bidder or contract price.
4) Do not do unfair transaction including boycott, maintaining resale price or combination sale.
5) In transactions with subcontractors, do not demand unfair price cuts, reject to receive, return goods or delay payment.

(2)

Appropriate Relationship with Business Partners

Do not give preferential treatment to specific customer and excessive requests to business partners; create and implement an appropriate relationship with business partners.

(3)

Prohibit the Special Treatment Provision

Do not offer any money, entertainment, gifts and other economic benefits which deviate from conventional wisdom to officers and employees of customers. Do not receive any economic benefits which deviate from conventional wisdom from officers and employees of customers.

(4)

Intellectual Property Right Protection

Understand that the intellectual property rights are the important company assets, and respect to other parties’ intellectual property rights and do not infringe the rights.

(5)

Prohibit Unfair Competition

Do not do unfair competition including procuring or using others’ trade secret illegally.

4. Share Holder・Investor Relationship

(1)

Publish Accurate Company Information to Public Promptly

Publish accurate company information of management policy, financial report and other related documents to public promptly in accordance with laws and regulations and regulations of securities exchanges for investor protection.

(2)

Appropriate Accounting Handling

Implement financial reporting and appropriate accounting handling with always ensuring accuracy based on the related laws and regulations as well as company rules in a timely and adequate manner. Do not contain any item that is false or may lead to misunderstanding in the accounting ledger.

(3)

Prevent the Insider Trading

Do not use any unpublished information for trading such as stocks trading and participate in the trading whether internally or externally when taking notice of important facts of the Company or business partners which may have a significant impact on investment decision of investors.

5. Aim to Better Corporate Culture

(1)

Respect to Company Asset

1) Understand that company assets are the sources of the company value, thus handle the assets carefully.
2) Adequately manage company funds and assets, and only use them for right purposes of business operation. Do not have off-balance funds or assets.

(2)

Handling of Information

1) Strictly control the company’s confidential information, customer information and personal information; do not disclose or offer such information to a third party except for the case required for the conduct of our business or other good causes; and do not use such information for the purpose other than our business.
2) Handle confidential information disclosed by a third party in the same manner as the company information.

(3)

Prohibit Conflict-of-Interest Act and the Mixing Up of Official and Personal Affairs

1) Do not do any act that may or is deemed to be a conflict with the company’s interest including working for a competitor or customer, or trading with the company for own interest.
2) Do not use the company’s assets and information system for the purpose other than the company’s business.
3) Do not engage in other occupations without the company’s approval.
4) Do not obtain shares of an unlisted business partner or an investee (including those under consideration) without the company’s approval.

(4)

Employment of Person with Disabilities

Respect human rights of all parties; do not discriminate on the basis of race, creed, gender, social status, religion, nationality, age or physical or mental disabilities.

(5)

Harassment

1) Do not do sexual harassment or other acts that may be misunderstood by others as sexual harassment. Do not conduct any sexual acts that make others feel uncomfortable.
2) Do not violate public order and standards of decency with actions which cause disruption in a healthy working place, environment and order. Never do any harassment using position and official authority based on the employment contract.

(6)

Protection of Whistle-blowers

Comply with the whistle-blowing system designed in view of protecting whistle-blowers and maintain the structure in which those who give reports to the Audit and Supervisory Committee will never be treated disadvantageously.

(7)

The securement of work environment I tend to do

Respect others’ personality and individuality to ensure that the Company’s officers and employees who have abundant individuality and diversity exercise their ability sufficiently; and strive to create open and desirable working environment based on free discussion and ensure its safety and sanitation.

(8)

Protection of a communicator of public interests

In accordance with the Whistle-Blower Protection Act, strive to maintain a structure in which whistle-blowers who have reported to internal or external section or administrative agency will never be treated disadvantageously.

(9)

Protection of Internal Whistle-blowers

In accordance with implementation regulations of the whistle-blower system, take every care that officers or employees who have reported or consulted concerning any illegal act or those who have cooperated in fact-finding will never be treated disadvantageously by reason of their reporting or cooperation, and that such treatment will never happen in working places.