Tsurumi Group Code of Conduct

I. General Provisions

1. Purpose

The Tsurumi Group Code of Conduct ("this Code") sets out the standards of conduct expected of all executives and employees of Tsurumi Manufacturing Co., Ltd. and its Group companies (Tsurumi Manufacturing's subsidiaries and affiliated companies etc.) ("the Tsurumi Group"). In implementing its corporate philosophy of "Being water- and people-friendly" through business operations, the Tsurumi Group expects each and every member to act in accordance with social ethics and in full compliance with laws and regulations.

2. Scope of Application

This Code shall apply to all executives and employees of the Tsurumi Group. However, with prior approval from the Board of Directors of Tsurumi Manufacturing, a Tsurumi Group company may modify the contents of this Code to comply with the laws and regulations, labor conditions, values, business customs and trade conditions of their respective country or region, provided that such modified Code shall not include any provisions that conflict with this Code.

II. Basic Attitude toward Business Activities

1. Approach to Business Activities

Upholding the corporate philosophy of "Being water- and people-friendly," the Tsurumi Group, as a manufacturing company, is always taking on new challenges with flexible imagination and abundant originality, seeking to create new currents in society by applying our original technologies, and striving to cultivate faith and trust while enriching people's minds.

2. Compliance with Applicable Laws and Regulations etc.

In every aspect of our corporate activities, we shall comply with all applicable laws and regulations, community rules and in-house regulations, including this Code. We shall strive to ensure that all our corporate activities comply with internationally accepted norms, social ethics and normal business practices.

3. Protection of Personal Privacy

We shall use for business purposes only any personal information of our customers, business partners and employees etc. acquired in the course of our work. We shall manage such information appropriately, to prevent leakage and privacy infringement.

4. Protection of Basic Human Rights

We respect basic human rights in every aspect of our business activities. We do not tolerate discrimination or any other conduct that violates the dignity of the individual on the basis of gender, age, birthplace, family origin, social status, nationality, race, ethnicity, creed, religion, disease and disability. Language or behavior that could be construed as sexual harassment will also not be tolerated. We strive to create a safe and pleasant working environment, where personality and individuality are respected so that all employees can fully demonstrate their capabilities.

5. Fair Trade

We shall maintain fair and honest relationships with all stakeholders and shall conduct transactions in a fair manner.

6. Improvement of Individual Morals

We shall not undertake any actions that may damage the Tsurumi Group's social trust or honor. We shall also not tolerate any action in pursuit of personal or third party interests against our company's legitimate interests. With keen awareness as a member of society, we shall always act responsibly as members of the company and in accordance with a good social conscience based on high moral and ethical standards.

7. Establishment and Operation of Internal Reporting System

The Tsurumi Group shall establish and maintain effective internal reporting systems, so as to encourage members to promptly report any acts that are or may be in violation of this Code, and so as to ensure that reported incidents are processed properly.
Anyone who, in good faith, reports acts violating this Code shall be treated fairly and with respect; no retaliation against such person shall be tolerated unless his/her reporting act is illegal. Names of whistleblowers shall be kept confidential to the extent possible.

III. Relations with Society

1. Preservation of the Environment

To protect the global environment, the Tsurumi Group shall not only comply with all applicable environmental laws and regulations, but also actively promote environmental activities, in line with its corporate philosophy of "Being water- and people-friendly." In upholding the environmental policy: "Realizing amenity-centric engineering for both people and earth," we will continuously strive to offer products needed for effective use of water-a precious resource. We will also strive to reduce the impact of our business activities on the environment, thereby helping conserve the global environment.

2. Donations/Political Contributions

The Tsurumi Group shall comply with all laws and regulations relating to donation. Prior to making any donation, we will investigate the organization to which we are considering a donation and how our donation will be used, and will carefully consider the necessity and appropriateness of any proposed donation.
We shall comply with all laws and regulations relating to political contributions and political activities, including the Political Funds Control Act and the Public Offices Election Act, and shall only participate in such activities - including contributions - as permitted by law.

3. Attitude toward Antisocial Forces and Organizations

The Tsurumi Group shall have no relationships with antisocial forces and organizations that pose a threat to the order and safety of civil society.

IV. Relations with Customers, Business Partners and Competitors

1. Provision of Safe, High-Quality Products and Services

In giving the utmost priority to customer safety, the Tsurumi Group shall not only comply with all relevant laws and regulations, but also strive to manufacture and supply products of superior performance, safety and reliability that meet customer quality requirements, in keeping with our corporate philosophy of "Being water- and people-friendly." By adhering strictly to our quality control policy, we will continue to provide safe, high-quality products and services.

2. Coexistence and Co-prosperity with Business Partners

The Tsurumi Group shall always treat all business partners, including suppliers of materials etc. and subcontractors for repair/construction work, in a fair and equitable manner, while complying with applicable laws, regulations and contracts.
We shall not take advantage of our position as buyers to unfairly harm the interests of suppliers. We shall also not seek personal gain by receiving benefits or special treatment in procurement or other purchasing operations.

3. Fair and Free Competition

The Tsurumi Group shall conduct fair transactions with all business partners, based on the principle of free competition and in compliance with anti-trust and fair trade laws and other applicable laws and regulations. We shall not engage in any action that inhibits fair and free competition, including collusion, nor shall we participate in meetings or in exchanges of information that may restrict free competition or engage in any activity that may be construed as doing so.
We shall always maintain open and fair relations with our customers, business partners and competitors. We shall also carry out commercial transactions with integrity, by adhering to social ethics.

4. Rules for Entertainment and Gifts

The Tsurumi Group shall adhere to sound business practices and social norms when providing or receiving entertainment or exchange gifts with business partners or others.
We shall not offer bribes to officials of public organizations (including former officials). In addition, we shall not provide any benefits to gain unfair business advantage, or offer entertainments, gifts or any other treatment that lacks justifiable grounds.

5. Export/Import Transactions

The Tsurumi Group shall carry out sound and fair import and export of products and technologies etc., in compliance with all applicable laws and regulations of the relevant countries and regions.
As a member of society who longs for world peace, we shall observe all applicable laws/regulations and rules of respective relevant countries and regions regarding the export of weapons and related technologies. We shall conduct appropriate export control to ensure that our products and technologies will not be misappropriated as tools that could threaten peace and security.

6. Appropriate Public Relations and Advertising

The Tsurumi Group shall avoid expressions that are not based on facts or that mislead or confuse customers with respect to the quality, performance or specifications of products or services in publicity, advertising and other sales-related activities.

V. Relations with Shareholders and Investors

1. Disclosure of Corporate Information

The Tsurumi Group shall provide shareholders and investors with corporate information, such as management policies and business activities, in accordance with applicable laws and regulations.
We shall disclose accurate corporate information in a timely and appropriate manner, with due consideration of the need to protect confidential information.

2. Prohibition of Insider Trading

All executives and employees of the Tsurumi Group shall not engage in any stock-related transactions based on non-public information obtained from the Tsurumi Group or other companies through execution of their work duties or business transactions.

VI. Management of Company Assets and Information

1. Management of Company Assets

All executives and employees of the Tsurumi Group shall properly manage the company assets in accordance with internal regulations, and shall not use such assets for other than business purposes.

2. Management of Confidential Information

All executives and employees of the Tsurumi Group shall strictly manage confidential information, including personal information, and shall not, either during their employment or at any time after termination of their employment, disclose, leak or wrongfully use such information.
Said executives and employees shall not disclose, leak or otherwise misuse any information obtained through execution of their duties concerning customers, suppliers or other business partners; nor shall they access or obtain by improper means confidential information relating to customers, business partners, competitors or public organizations.

3. Management of Intellectual Property Rights

Recognizing the importance of intellectual property rights, including trade secrets, all executives and employees of the Tsurumi Group shall respect the intellectual property rights of third parties, and shall protect and safeguard its own rights.

VII. Supplementary Provisions

1. The Tsurumi Group shall appoint the chairperson of the Compliance and Risk Control Committee as the person responsible for management of this Code.
2. The Tsurumi Group shall organize the Compliance and Risk Control Committee, which formulates proposals for revision of this Code, develops training programs for this Code and checks implementation status.