IBIDEN Group CSR | Basic Policy

Behavior standards governing employees' personal business transactions and private life

Insider trading

1. Basic attitude

Working for the company sometimes leads to the acquisition of important undisclosed information on the company or other business enterprises. Using such information, before its public disclosure, for transactions in the company's or other business enterprises' securities constitutes "insider trading," which is prohibited by law.
Insider trading will always be strongly censured and penalized because it destroys the confidence of individual stockholders and impairs relationships of mutual trust with business partners.
Officers and employees shall comply with the regulations in the Securities and Exchange Law that prohibit insider trading.

2. Behavior standards

(1) Inside information and its management
The company's officers and employees shall gain a good understanding of the company's rules on insider trading management to ensure that unfair leakage of inside information*11 is prevented.
(2) Prohibition of insider trading
If any officer or employee has acquired inside information held by the company, one of its subsidiaries, or any other business enterprise in connection with his or her duties, he or she shall not trade in its securities in his or her personal capacity or in the name of the company (Ibiden) before the official release of such information. In addition, such an officer or employee shall not trade the aforementioned securities in the name of one of his or her family members or any other person.
Officers and employees who have acquired inside information shall not communicate it to anyone except in cases where such communication is necessary for the performance of their operations.
Officers shall comply with the regulations in the Securities and Exchange Law that prohibit them from trading the company's own stocks.

11) Inside information means undisclosed information that is defined as such by laws including the Securities and Exchange Law and that may exert an influence on individual investors attempting to make a decision on their transactions in stocks and other securities (this type of information is also called "material facts").
For example, such information relates to business collaboration, the development and announcement of a new product, financial performance (sales, profits, dividends, etc.), and other information on activities and the like having a significant influence on the company. The information is classified as inside information until its official release by the company. When in doubt, consult the divisions concerned for legal definitions of and management methods for inside information (laws and the company's rules on insider trading management contain some applicable provisions).

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Political or religious activities and behavior as a consumer

1. Basic attitude

The company encourages officers and employees to participate in politics. Political activities, however, represent a part of an individual's personal life. For this reason, political activities may not be carried out on the company's premises without the company's permission.
The company does not support or discriminate against religions. The company never interferes with personal religious activities except in special circumstances ,for example, when the performance of operations is affected. Religious activities, however, also constitute a part of an individual's personal life. For this reason, religious activities including proselytizing may not be carried out on the company's premises unless otherwise agreed.

2. Behavior standards

(1) Participation in political activities
Participation in politics through voting and other means is one of the obligations of a citizen. Officers and employees are therefore encouraged to participate actively in the political process.
If, however, participation in political activities affects operations, officers and employees shall obtain the prior approval of their immediate superiors.
When expressing views on political issues, officers and employees shall make it clear that their views are entirely personal.
(2) Religious activities
Religious activities represent a part of an individual's personal life and are therefore left to the discretion of each individual. Officers and employees, however, shall exercise due caution to ensure that such activities do not interfere with the company's operations.
(3) Prudence as a consumer
Officers and employees shall endeavor to acquire a correct knowledge that enables them to avoid running into trouble relating to consumer finance services or credit services. In seeking any such services, officers and employees shall ensure advance planning in consultation with their family members. In the event officers or employees have difficulty adhering to the repayment schedule or encounter other kinds of problems, they shall immediately consult family members, lawyers, or other relevant persons.
Officers and employees shall acquire a correct knowledge about illegal business practices such as multilevel marketing to avoid the potential financial damage associated with such practices. If asked by any acquaintance to purchase a product relating to such business practices, officers and employees shall firmly decline the request as this is in his or her best interests. In the event of actual or expected damage, family members, lawyers, or consumer affairs bureaus shall be consulted.
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Traffic safety

1. Basic attitude

The company is committed to ensuring traffic safety on a group-wide basis through the Ibiden Group Traffic Safety Committee.
Each officer and employee shall endeavor to eliminate traffic accidents so that no one will be the victim of or be responsible for any traffic accidents.

2. Behavior standards

(1) Compliance with traffic rules
Officers and employees shall comply with traffic rules to avoid causing accidents. Each employee shall make sure to fasten his or her seat belt and drive at a moderate speed.
Officers and employees shall never drive under the influence of alcohol, to any degree whatsoever.
(2) Improvement of traffic manners
When driving an automobile, officers and employees shall show consideration and kindness to others. For example, they shall endeavor to give way to other drivers and to prevent accidents involving vulnerable road users such as children and elderly people.
(3) Responses to traffic accident
If any officer or employee encounters a traffic accident, he or she shall immediately render assistance to the injured person(s), call an ambulance, and contact the police. At the same time, he or she shall report the accident without delay to insurance companies, the company (Ibiden), and other parties.
If any officer or employee causes a traffic accident, it is especially important for him or her to (i) offer the police his or her fullest cooperation at the post-accident police interview and to (ii) provide compensation to the victim(s) in good faith after full consultation with parties including insurance companies.
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