Compliance Guidelines

For each member of the AMITA Group (hereafter, "Group"), compliance denotes conforming to social expectations by complying with laws, regulations and rules, while also exhibiting a strong sense of morality and ethics, and conforming to norms of behavior. Based on a recognition that compliance is essential to the Group's healthy development, these Compliance Guidelines set forth the key matters to which corporate officers and all employees (hereafter, "Group employees") must conform.

1. Basic stance on behavior

i) Observance of compliance

Always undertaking work duties with a strong sense of ethics and observing social norms, the Group employees must abide by all applicable laws and regulations, socially acknowledged standards and rules, contracts and arrangements with clients, and organizational rules and manuals.

ii) Acting from the other person's perspective

In dealings with clients, shareholders, colleagues, etc., Group employees should act based on an understanding of the other person's perspective.

iii) Compliance takes priority

When business profits and requests from others come into conflict with the Compliance Guidelines, compliance should be given priority.

iv) Obligation to report

The discovery of any instance of a compliance violation, or concern about a compliance violation, whether or not it concerns the person making the discovery, should not be concealed but should be reported to a superior or brought to the attention of the contact point tasked with receiving such reports in the "Compliance Rules".

2. Respect for basic human rights

i) Respect for human rights and no discrimination

Group employees should respect basic human rights and exercise no discrimination with regard to nationality, ethnicity or race, religious creed, political belief, sex, personal origins or ancestry, disability, or age.

ii) No harassment

No form of harassment shall be tolerated, including but not limited to cases where gender, power or status frames a choice of language or behavior that demeans an individual.

iii) No forced labor or child labor

The Group shall not engage in any form of forced labor or child labor.

3. Fairness and sincerity in business activities

i) Appropriate business with clients

Respecting each other's status, rights, and profits, as well as complying with laws and regulations, the Group shall seek to maintain equal and fair dealings with clients.

ii) Fair competition

Seeking no hindrance to fair competition, the Group shall impose no improper restrictions on business and employ no unfair means of doing business.

iii) Accuracy of financial reporting

Regarding the recording of accounts and financial reporting accompanying business activities, the Group shall constantly strive for accuracy and not undertake any deliberate falsification, or engage in any act of falsification.

iv) Disclosure of relevant information

The Group shall strive to promote understanding of the Group's activities in society at large by maintaining the transparency of corporate activities and disclosing relevant information. Moreover, in accordance with applicable laws and regulations, the Group shall accurately and fairly disclose to shareholders, investors and others the Group's business situation including financial details and the state of business.

v) Healthy relations with politics and public administration

The Group shall always maintain healthy and transparent relations with representatives in politics and public administration, making no illegal donations, extending no favors, and offering no bribes.

vi) Limits on gifts and entertainment, etc.

In order to maintain healthy relations with clients, etc., the Group shall avoid any action whose fairness might be questioned, such as offering or accepting gifts or entertainment that exceed socially accepted norms.

vii) No association with antisocial elements

The Group shall take a resolute stand against, and maintain no association whatsoever with, any antisocial or unlawful activity or force that threatens the order and safety of society.

viii) No insider trading

Understanding the purport of insider trading regulations, the Group, in the case of any important information that comes to be known prior to its public disclosure, shall keep that information secret until it is publicly disclosed. Moreover, no act shall be undertaken that seeks to obtain a profit from information, obtained in the course of duties, that is undisclosed to the public and concerns either the Group or a client. Such prohibited acts include the sale of stock (insider trading).

4. Protection and preservation of assets and information

i) No misuse of Group assets

Group assets shall be appropriately managed and used. They shall not be subject to such violations as the pursuit of dishonest goals, including the use, for personal gain, of Group products, facilities, equipment, information, intellectual property or other tangible and intangible Group assets.

ii) No action resulting in a conflict of interests

No act shall be undertaken that seeks profit for the perpetrator, or for relatives, friends or acquaintances of the perpetrator, at the expense of the Group's own profits. This includes undertaking, or being involved in, business activities that compete with those of the Group, or working for rival entities.

iii) Protection of intellectual property rights

Intellectual property rights including patents and copyrights possessed by third parties shall not be infringed.

iv) Protection of confidential information

Confidential information that comes to be known about the Group or a third party in the course of business, such as trade secrets, or information about technology and knowhow, shall be administered with strict care. In the absence of permission this information shall not be disclosed or leaked to a third party, or any individual in the Group who has no need to know the information for business reasons. Nor shall the information be used for any purpose other than the purpose for which it was originally intended.

v) Protection of personal information

Personal information that comes to be known in the course of business about a Group employee or a third party, such as a Client, shall be administered with strict care. Except when the person concerned has given prior agreement, this information shall not be disclosed or leaked to a third party, or any individual in the Group who has no need to know the information for business reasons. Nor shall the information be used for any purpose other than the purpose for which it was originally intended.

5. Safety considerations

i) Security

Recognizing that ensuring safety is a social obligation of the enterprise, the Group shall always assign top priority to safety in all business processes and activities, such as ensuring the safety of products and services, and ensuring the safety of work procedures.

ii) Industrial health and safety

In addition to the observance of rules established for compliance with laws and regulations concerning industrial health and safety, and for prevention of industrial accidents, the Group shall seek to ensure health and safety, and promote the establishment of a comfortable working environment. No action shall be undertaken that opposes such efforts.

6. Consideration for the environment

i) Reducing environmental impacts

Recognizing that the establishment of a cyclical system is the top priority for achieving a sustainable society, the Group energetically promotes efforts to reduce environmental impacts in business activities and in all business processes.

ii) Waste regulation

The Group shall observe laws and regulations concerning the processing of industrial waste emitted as a result of business activities, as well as laws and regulations concerning recycling and the effective use and conservation of resources.

iii) Preventing pollution

To conserve and protect the environment, the Group shall observe laws and regulations concerning the prevention of pollution in such forms as air pollution, water pollution, noise, vibration, offensive odors, soil contamination, and dioxins.

Supplementary provision

The revision or abolition of these guidelines shall be subject to a resolution by the Group's Board of Directors, following endorsement by the corporate officer in charge of compliance.