Based on our corporate vision of “effectively using limited global resources and contributing to society through our business,” this “Matsuda Sangyo Group Global Code of Conduct” (the “Global Code of Conduct”) of Matsuda Sangyo Co., Ltd. (“Matsuda Sangyo”) provides the basic principles to be observed in order to contribute to society in accordance with the conscience of corporate citizens as the foundation of all business activities.
The Global Code of Conduct is considered to be the highest in-house standard for business activities and other social activities, and represents the appropriate actions that reflect Matsuda Sangyo’s corporate vision, laws and regulations to be observed, and social demands.
In the event of a breach of the Global Code of Conduct or a possible breach, the Matsuda Sangyo Group will promptly take appropriate corrective measures.
The Global Code of Conduct shall apply to Matsuda Sangyo and its group companies (meaning the companies in which Matsuda Sangyo directly or indirectly holds a majority of the outstanding shares with voting rights or the equity, and companies in which Matsuda Sangyo has substantial control; collectively, the “Matsuda Sangyo Group”) and its directors and employees (including, but not limited to, directors, executive officers, advisors, consultants, full-time employees, temporary and part-time employees, among others) who work for Matsuda Sangyo and its group companies (collectively, the “Executives and Employees”).
１ Compliance
As a member of the international community, we will conduct our business activities in good faith in compliance with all applicable laws and regulations that are required for our business activities.
We will act with common sense and integrity as a corporate citizen.
２ Social Contribution
（１）Meeting Social Demands
As officers and employees of the Matsuda Sangyo Group, we are aware that all our business activities have an impact on society and our stakeholders, and we will act to meet social demands.
（２）Towards a Sustainable Society
We will strive for a sustainable society, and act in accordance with our long-term management plan, taking into account the environmental, social, and economic impacts of our business activities.
３ Business Activities
（１）Fair Trade
We will conduct business fairly based on free competition.
The selection of suppliers will be based on objective facts such as price, quality, and delivery date of products and services, taking into account whether the suppliers are conducting activities in accordance with the Global Code of Conduct.
（２）Pursuit of Product and Service Quality
In order to ensure the quality and safety of the Matsuda Sangyo Group’s products and services, we will thoroughly verify quality control and check security risks.
We will constantly strive to develop innovative technologies to enhance the value of the Matsuda Sangyo Group’s products and services.
（３）International Trade
We will comply with the export and import laws and regulations of the countries in which we engage in international trade and will prevent improper conduct.
（４）Financial Management
We will pay taxes appropriately in accordance with the laws and regulations of the countries and locations in which we operate, and will accurately and completely record all financial information, and report such information within the appropriate accounting periods.
We make no misstatements or false reports on financial information.
（５）Non-use of Conflict Minerals
In the procurement of mineral resources, we will not use conflict minerals that are suspected to have been procured through the involvement of armed groups or child labor.
（６）Money Laundering
We will not engage in money laundering of funds or precious metals that are obtained through illegal activities and whose sources are undisclosed.
（７）Insider Trading
Through our business activities, we will not inappropriately disclose our internal or non-public information or such information obtained from our business partners, and will not sell or purchase stocks or other financial instruments for our benefit of that of specific individuals based on such information.
（８）Discontinuation of Relations with Anti-social Forces
We will not in any whatsoever, whether directly or indirectly, become involved with anti-social forces or organizations that interfere with proper business activities.
（９）Bribery and Corruption
We will not entertain or provide gifts to customers, prospective customers, business partners, suppliers, among others, in contravention of laws and appropriate social practices.
We will not entertain or provide gifts to government officials in Japan and overseas or to foreign public officials in contravention of laws, regulations, and social practices.
（１０）Conflicts of Interest
Through our business activities, we will act appropriately and in the best interests of the Matsuda Sangyo Group.
We will not engage in any acts that conflict or may conflict with the interests of the Matsuda Sangyo Group.
（１１）Robust Risk Management
We will identify and prevent various risks within the Matsuda Sangyo Group. In the event of any kind of risk arising, we will take prompt action.
（１２）Anti-fraud Measures
Where we detect improper acts, such as violations of laws and regulations, or acts that may be improper, through our business activities, we will promptly investigate and take corrective measures to prevent the recurrence of such violations and firmly deal with such violations.
（１３）Business Continuity
In preparation for various disasters, we will put in place disaster and business continuity measures to protect against loss of life and ensure business continuity.
４ Preservation of Corporate Assets and Information
（１）Preservation of Corporate Assets
We are always aware of our responsibility to preserve the Matsuda Sangyo Group’s corporate assets, and we will only use them in duly authorized business activities.
We will not use the Matsuda Sangyo Group’s corporate assets privately under any circumstances whatsoever.
（２）Protection of Company Confidential Information
We will protect all corporate information, including information received from customers and business partners and confidential information held by the Matsuda Sangyo Group.
We will strive to prevent the loss or theft of such information, and will not disclose such information without due authorization.
（３）Intellectual Property Protection
We will protect all intellectual property that arises from R&D activities conducted for the purpose of the development of the Matsuda Sangyo Group.
We will not infringe or improperly use the intellectual property of the Matsuda Sangyo Group or that of any third party.
（４）Protection of Personal Information
We will respect the privacy of Matsuda Sangyo’s directors and employees, stakeholders, and all others connected to the Matsuda Sangyo Group. We will appropriately acquire, properly use and manage personal information.
We will put in place an appropriate information security environment, and will not leak or destroy personal information.
（５）Proper Dissemination of Information
When communicating internally and externally via documents and e-mails, we will do so using proper procedures.
We will not provide information on our company’s business through social networking services, and other forms of social media, without obtaining due authorization.
５ Respect for Human Rights
（１）Respect for Human Rights and Fair Labor Practices
We will respect internationally recognized human rights, and violations of human rights, including forced labor, racial discrimination, child labor, and harassment, will not be permitted.
（２）Safe and Hygienic Working Environment
We will strive to create a safe and hygienic workplace environment to prevent accidents and illnesses in the workplace.
（３）Realizing Comfort and Prosperity for Directors and Employees
We will strive to improve working conditions, realizing economic, mental, and time-related comfort and prosperity for directors and employees.
（４）Creating a Workplace where Employees can Leverage Individuality and Dynamism
We will strive to create a workplace in which all directors and employees of the Matsuda Sangyo Group can maximize their individuality, motivation, and abilities.
（５）Prohibition of Disadvantageous Treatment
We will not engage in detrimental treatment or retaliation against any person who has reported or consulted in good faith or who has cooperated in an investigation.
６ Environmental Preservation
（１）Effective use of global resources
We will make effective use of global resources in the procurement of raw materials and in the purchase of goods under our precious-metals- and foodstuff-related businesses.
（２）Preservation of the global environment
In consideration of the preservation of the global environment, we will comply with laws and regulations related to waste disposal, as well as environmental laws and regulations, and will ensure that the necessary permits and approvals are obtained and appropriately renewed.
In undertaking our corporate activities, we will strive to prevent pollution by contributing to the reduction of our environmental impact and to create a recycling-based society.
Supplementary Provisions: effective as of July 1, 2020
