In order for the Sharp Group companies (Sharp Corporation, its subsidiaries and affiliated companies in which Sharp Corporation holds a controlling interest) to put the content of The Sharp Group Charter of Corporate Behavior into practice in their daily business activities, and thereby fulfill our social responsibility, “all officers and employees of the Sharp Group companies” (hereinafter called “we”) are obliged to comply with the provisions of the "Code of Conduct" as set out here-below upon performing the corporate tasks assigned to them to which the regulations exclusively relate.

(I) Practice of Fair and Open Management

1. To Practice Legal Compliance, Ethical Business Conduct, and Fair and Impartial Management:

1.  In our corporate business activities and the performance of our job tasks, we will comply with all national and local laws and regulations, as well as international rules and internal company rules, and will follow accepted social norms and business ethics, and will take reasonable actions.

2. In our business activities, we will not engage in questionable acts from the standpoint of business ethics, such as making false, misleading or fraudulent reports, or committing individual acts or engaging in behavior which conflicts with the interests of the Sharp Group companies.
Furthermore, whenever it seems that our individual acts or behavior upon performing the corporate tasks assigned to us may conflict with the interest of the Sharp Group companies, we will, in advance, inform our superior or the responsible department in detail. We will put the acts or behavior into practice only when the company confirms that there will be no conflict.

3. We will work to be cooperative for the maintenance of social order, and will not be knowingly involved with anti-social activity.

2. To Respect the Cultures and Customs of the Countries and Communities Where We Do Business:

When in charge of international business, we will work to contribute to building a relationship of mutual cooperation and trust with local businesses, starting with complying with international rules and local laws and regulations. In addition, we will work to understand the situation in the local community, and along with conducting business operations by giving full consideration to the local culture and customs, we will also strive to participate in community service and social action programs in the markets we operate in.

3. To Prevent Corruption such as Extortion and Bribery:

1.  At home or abroad, we will not entertain, nor give money or goods to public officials (and the like), which is prohibited by applicable laws and regulations in each country and region.

2. We will keep the giving and receipt of other monetary rewards or gifts, as well as business-related entertaining, within reasonable bounds. We are going to determine guidelines relating to the type and frequency, so as to avoid going beyond socially acceptable courtesies in each country and region.

4. To Handle Monetary Gift Contributions and Political Donations Fairly and Appropriately:

1.  Regarding contributions and gifts of money, we will proceed strictly in conformance with relevant laws and regulations, as well as relevant internal company rules, in order to ensure that they do not fall under the category of payoffs or illegal payments.

2. We will observe Company policy that political donations should be confined to the absolute minimum necessary given the level of engagement with the local community, as well as in compliance with applicable laws and regulations, and that when making such contributions, we will proceed in strict conformance with relevant internal company rules.

(II) Enhancement of Customer Satisfaction

1. To Create and Supply Innovative, Original Products and Services that Meet the Needs of Customers:

1.  We will constantly work to conduct surveys and do research to accurately ascertain the needs of our customers.

2. We understand that innovative, original products and services are those that produce a positive impression on customers and that have utility even when viewed from the perspective of saving resources and preserving the environment, and we will work to develop business models and key technologies which will form the core of such products and services.

2. To Ensure the Safety, Quality and Reliability of Products and Services:

1.  In all countries and regions where we do business, we will conduct our business activities in compliance with all safety laws and regulations, and safety standards applicable to products and service, as well as in accordance with internal company rules.

2. Remaining ever mindful that “Quality First in Heart and Mind,” we will make safety and quality our first priority. For this reason, we will always build on the following points in conducting our business activities:

Take every possible measure to maintain product safety and quality, and stand behind them.

Pursue safety to the greatest extent possible at every step—from research and development, to production, distribution and after-sales service.

 Make the utmost effort to prevent the occurrence of accidents and problems by providing clear, easy-to-understand instruction manuals, and by ensuring that products bear effective labeling for proper and safe use.

3. We will always evaluate the safety, quality and reliability of products from the customer’s point of view.
Should a product or service distributed or provided by the Sharp Group companies have caused damage or injury to the life, person or property of a customer, or that there is a risk of same, or in the event that a product quality issue has arisen that reflects on the good reputation of the Company, we will promptly mount an appropriate response in accordance with rules established by the Company, including immediately notifying our superiors.

3. To Gain the Trust of Customers and Ensure Their Satisfaction:

1.  We will conduct sincere and good-faith business operations and service operations, taking into account the social conventions of each country and each region.

2. We will handle inquiries and complaints from customers in a kind, courteous manner, in accordance with internal company rules and guidelines, giving full consideration to the viewpoint of our customers, in order to deliver the ultimate in satisfaction to them. In addition, we will strive to act in a manner that exceeds customer expectations by quickly verifying the matter, and making a good-faith effort to deal with it. We will also provide appropriate feedback on major complaints to the related departments including quality and reliability control departments in order to prevent similar problems.

3. To take full advantage of the opinions and needs of customers, which we regard as basic information necessary to conduct our business activities, we will provide immediate feedback of the information to the relevant departments, including development and engineering, product/service planning, and quality control departments.

(III) Disclosure of Relevant Information /Protection and Security of Information

1. To Protect the Privacy of Personal Information:

We will strictly manage personal information which has been obtained with the consent of customers, business partners, suppliers or employees, to prevent it from being used for any purpose other than that disclosed at the time it was obtained. We will also protect the information in a way that prevents the contents from being divulged or tampered with.

2. To Disclose Relevant Information in a Timely and Appropriate Manner:

1.  In order for the Sharp Group companies to increase the transparency of our business operations and fulfill our obligations regarding corporate accountability through the disclosure of corporate information in a timely and appropriate manner to shareholders, investors and other stakeholders, we will work to compile information with a high regard for accuracy and fairness and promptly generate reports for our superiors.

2. We will provide information to customers related to the functions and features of our products and services, as well as information on the correct way to use them and precautions for their use.

(IV) Contribution to Conservation of the Global Environment

1. To Conserve the Environment:

1.  We will comply with all applicable environmental laws, regulations and territorial agreements, and work to practice efficient use and conservation of resources and energy voluntarily, in the recognition that environmental conservation is an essential facet of corporate and individual pursuits.

2. We will ensure proper use and control of chemical substances in our business activities including research, development and manufacturing, meeting or exceeding levels determined by laws and regulations.

3. We will engage in the active acquisition, reporting and promotion of environmental information at an international level, as the Sharp Group companies promote communication with shareholders and local residents.

4. We understand the importance of internal company systems and related details in acquiring third-party certification and recertification of our ISO environmental management systems, and we will conduct our business operations in accordance with relevant internal guidelines.

2. To Develop Environmentally Conscious Products and Services, and Conduct Our Business Operations in an Environmentally Conscious Manner:

1.  We will engage positively in the minimization of resource use, reduction in the size and weight of products, use of recycled materials, and the development of long-lasting, energy-saving, energy-creating products.

2. We will work to compile information related to harmful substances that might damage the environment or human health, and will not, as a matter of principle, make use of these harmful substances in our products, services and business activities.

3. We will use recyclable materials wherever possible, with product development focused as a matter of policy on structures that are detachable or capable of dismantling, and suited to recycling.

4. We will work aggressively to reduce greenhouse gas emissions in the full range of our business activities, in order to contribute to the prevention of global warming.

5. We will work to conduct our business in such a way to select and purchase materials that are harmless to the global environment, and to local residents and employees, for the resources needed for business activities (equipment, raw materials, subsidiary materials, tools, etc.).

6. We realize that waste material is a valuable resource, and we will actively conduct our business operations in such a way as to maximize the 3Rs (reduce, reuse, recycle) and will contribute to minimizing the amount of waste sent for permanent landfill disposal.

(V) Sound, Equitable Economic Activities

1. To Engage in Free, Equitable Competition and Provide our Customers with High-Quality,Moderately Priced Products and Services:

1.  We will take no part in cartel activities or in collusive bidding practices.

2. We will not engage in imposing re-sale price restrictions, tied sales, or other conduct that constitutes unreasonable restraint of trade or restrictions with regard to business transactions with our business partners.

3. We will not engage in acts that constitute unilateral changes in trade terms and conditions, compulsory purchasing, or similar acts that take advantage of our position of superiority.

4. In advertising and the like, we will make representations based on substantial, objective grounds, and will not engage in acts that constitute false or misleading advertising. Also, we will not offer excessive premiums as an accompaniment to sales or employ deceptive sales practices.

5. In addition, we will not engage in actions that violate the provisions of competition and representation-related laws.

2. To not Engage in Unfair Competitive Acts:

1.  We recognize that divulging technological or business secrets of the Company (trade secrets) would cause a great loss to the Company, and we will manage and protect these trade secrets as well as not divulge or disclose trade secrets to others, nor make fraudulent use of a trade secret.

2. We will not acquire the trade secrets of third parties by improper means. Also, we will not acquire trade secrets of third parties while being aware that such trade secrets have been acquired through improper acquisition.

3. We will not distribute false information injurious to the business reputation of a competitor.

4. We will not use objects or designs identical or similar to the trade representation of goods of third parties in the representation of products, etc., of the Company. In addition, we will not engage in acts that constitute imitation of the configuration of the product of a third party.

3. To Respect Intellectual Property Rights:

Based on the recognition that intellectual property rights and know-how (“IPRs”), such as patents, utility models, registered design rights, trademarks, and copyrights which the Company has acquired through investment, are important assets of the Company, we will work constructively to create intellectual property, and in the event we create intellectual property in the course of company business activities, we will report this fact to the Company without delay, and will cooperate with the Company in applying for patent and other IPRs and in protecting and managing those IPRs. In addition, we will respect the IPRs of third parties in new technology research, product development, production and marketing, and will not consciously infringe on these rights.

4. To Fully Enforce Restrictions on Exports Subject to Security Trade Control:

1.  In the event we are involved in the export of any and all goods and in providing technology from the Sharp Group companies, we will conduct a prompt, careful investigation into whether they are restricted by the provisions of laws related to export controls for the maintenance of international peace and security of the relevant country or region, and further, we will determine whether the potential exists for their being used in applications such as weapons development based on the application, end-user and mode of transaction.

2. Regarding goods and technology that have been confirmed for export, we will follow all required export procedures in accordance with relevant laws and regulations, and relevant internal company rules.

5. To Practice Fair, Appropriate Purchasing Activities:

1.  In selecting a vendor or supplier, we will conduct a fair, transparent evaluation and assessment based on our position with respect to economic reasonableness, and in consideration of the legal compliance and business ethics of the target corporation. Recognizing Sharp’s position as a multinational enterprise doing business around the world, we understand the need to conduct fair transactions and will carry out our business activities by opening doors widely without discriminating between domestic and foreign companies.

2. Based on compliance with laws and regulations related to purchasing transactions in each country or region, we will not engage in acts that are questionable from the standpoint of business ethics.

3. We will not accept gifts or business entertainment from existing or potential new suppliers/vendors that go beyond the bounds of the socially accepted business practices of the country or region in question.

6. To not Engage in Insider Trading:

1.  In the event we are in a position to have ready access to information that has the potential to have a significant effect on the price of stock of the Sharp Group company listed in stock mars or that of our business partners, or in the event we gain access to such information through or as a result of our job tasks, we will take no action that may constitute insider trading, such as buying or selling shares prior to the public announcement of the information in question.

2. We will not give such information, which may constitute insider trading, to third parties customers, family members, friends and etc.) as well as directors and employees of the Sharp Group companies who are not concerned with the matter relating to the information in question.

(VI) Respect for Human Rights

1.  In the full range of our business activities, we will respect the fundamental human rights and the dignity of the individual, and will not engage in actions, such as harassment, the expression of contempt, verbal abuse, or unreasonable coercion that take advantage of our official or business position.

2. We will take no part in, nor sanction, child labor or forced labor.

3. We will take no action that constitutes discrimination based on nationality, race, color, sex, age, religion, creed, social status, birth, property, physical handicap or disability, political opinion, and the like.

4. We will not engage in actions that constitute sexual harassment, such as non-consensual sexual remarks or behavior toward another person, in the office or in other job-related places, which are evidently rejected by the person concerned.

(VII) Creating a Safe, Fair, Motivating Work Environment

1.  We will be actively involved in creating a safety-first workplace environment by placing maximum priority on human life, and as respecting the laws and regulations, and internal company rules relating to occupational health and safety. In addition, we will proactively take part in measures related to disaster prevention and an appropriate emergency response in case of disaster.

2. We will actively cooperate in enhancing the work environment so that challenged, elderly and otherwise impaired employees can fully demonstrate their abilities.

3. We will respect the personality and individuality of each employee, in order to foster a workplace atmosphere that emphasizes individual initiative and creativity, and where all employees may fully display their abilities for achievement of business objectives.

4. We will not defame or slander a company or person.

5. As an employee working for a corporation, we will apply common sense, and will work to improve ethical standards and good manners to the extent that can be reasonably expected of us.

6. We will work to make our business operations more streamlined and efficient, and will take up new themes with positive determination.

7. We will properly manage all types of Company assets (tangible and intangible assets, including information, products, equipment, tools, consumables, intellectual property, and brands) in accordance with prescribed internal company rules, and will not misuse or make improper use of them (uses other than for purposes of business activities, such as diverting to personal use or use for a third party).

8. We will understand the business risks related to each of own job tasks, and will work together with persons in authority such as our superiors to take proactive measures to prevent accidents.

(VIII) Harmony with the Community

1.  We will work to engage in contributions to the local community through participation in, donation to, and support for or co-sponsoring of community events resp. non-profit activities.

2. We will work actively to support academic research, preservation of the environment, educational, cultural and art activities.

3. We will work to take active part in volunteer activities.

(IX) Implementation of The Sharp Code of Conduct

1. Administrative System

1. Under a resolution passed by the respective Boards of Directors of the Sharp Group companies, the Sharp Code of Conduct will apply to each company.

2. To conform with the laws, regulations, and customs of a country or region in which a Sharp Group company is located, it may make changes to the Sharp Code of Conduct to the extent that they do not violate the underlying purpose and intent thereof. It should also be noted that any changes made must be approved by a resolution of the Board of Directors of each company, and prior notification must be made to the under-mentioned Contact at Sharp Corporation.

3. The Sharp Code of Conduct will be reviewed and revised as necessary, and in such case, the Sharp Group companies will keep all employees notified of any revisions at all times.

4. The Sharp Group companies will prepare and distribute a Sharp Code of Conduct Handbook, to promote employees’ acquaintance with the code.

5. The Sharp Group companies will take measures including training programs, etc. from time to time to familiarize employees with the Sharp Code of Conduct.

2. Contact

Questions and comments related to the Sharp Code of Conduct may particularly also be raised and referred to the following departments: CSR Promotion Department, Management Planning Board, or to the General Affairs Department of the Human Resources Group of Sharp Corporation.