TMJ Code of Conduct

We believe that it is our “social responsibility” to exert outstanding expertise in our contracted operations and to contribute to the growth of our clients’ businesses. TMJ is currently expanding its business widely not only in Japan but also overseas. In such a variety of environments, in order for diverse human resources to demonstrate their outstanding expertise and contribute to the business growth of clients, the “values” and “judgement criteria” common to all executives and employees are necessary.

Hence in October 2013, we formulated a code of conduct, clarifying the values and judgment criteria that all executives and employees working at TMJ’s group of companies should protect. In making the code of conduct, we held a code of conduct training for all officers and employees, and would continue to require educating them on the subject. Furthermore, by establishing a mechanism in the company to be able to return to the code of conduct whenever necessary, employees are engaged in activities to understand, discuss, and practice the code of conduct.

1. Compliance with the law

1-1 Basic attitude

The Company recognizes that compliance is the most important code of conduct to continue its business operations in the society, and to require the executives and employees to practice and comply not only with laws and regulations but also the moral and business ethics behind them.

1-2 Compliance with the Law / Practice of Appropriate Judgment Process

Executives and employees recognize not only the relevance of the results but also the importance of the process leading to the conclusion, and decision-making always requires factual-based discussions and considerations, and proper approval procedures. In addition, we main

2. Promote social communication

2-1 Communication with society, information disclosure, information protection

The Company recognizes that it has social responsibilities to a wide range of stakeholders including clients and their customers, partners, employees, shareholders, local communities, government, etc. In an event of significant impact to stakeholders occurs, we will work on solving common issues through two-way communication in addition to timely and appropriate accountability.

2-2 Response to globalization

With response to the globalization of business activities, the Company handles the management in consideration of the laws, regulations, culture and customs of each country/region in which we operate, and give a new sense of value by contributing to the country and/or the region’s economic development.

3. Social relations

3-1 Social contributions

In order to fulfill its social responsibility, the Company recognizes that it is a request from stakeholders to directly or indirectly address issues and problems the society is facing while taking the business philosophy into account, identify the tasks to be prioritized, and promote activities that contribute to the society.

3-2 Regional contributions

Aside from contributing to regional revitalization such as the creation and promotion of employment by attracting business projects and the like, the Company actively participates in various initiatives in the area, aiming to work in harmony with the locals to contribute to the fulfillment of making a rich and pleasant community.

4.Environmental protection contributions

4-1 Environmental conservation

The Company considers the environmental impact of the services and performing businesses provided, and strives to reduce it as much as possible, such as using energy-efficient equipment, reducing and separating waste, etc.

5. Approach to service

5-1 Developments, provisions, and quality of services

The Company will develop and provide socially useful services to meet the needs of clients and their customers, and strive to ensure quality and realize client value.

5-2 Service information dissemination

The Company will always provide appropriate information on our sales activities for clients, as well as information dissemination through websites, and in advertising activities through seminars, lectures and other media.

5-3 Response to inquiries, quality improvement, and new service development

The Company responds promptly and honestly to the needs of the clients and their customers, promote employee awareness, and not only improve their services, but also actively make recommend

6. Establish partnerships with clients and business partners

6-1 Fair, Transparent, Free Competition and Fair Trade

The Company does not act to inhibit fair, transparent or free competition through unfair trading methods, abuse of superior status, etc.

6-2 Limitations on gifts and entertain

The Company will not accept or receive any form of entertainment, money, gifts or other benefits from clients or partner companies for the purpose of acquiring unfair benefits etc. beyond the scope that is socially acceptable.

6-3 Appropriate display implementation

We strive to achieve fair and transparent competition without giving false, incorrect, and/or misleading indications about the services we provide.

6-4 Purchasing activity

The Company will establish an appropriate outsourcing and purchasing transaction policy, conduct a thorough evaluation in selecting a partner company, and conclude with a proper contract.

In addition, the Company strives to build and maintain long-term trusted relationships with partner companies by complying with document orders and payment dates stipulated in the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors, and eliminating unfair transactions due to abuse of superior status.

6-5 Reasonable contracts

In contracts with clients and partner companies, the Company grasps the risks and costs accordingly, and enter into contracts that describe appropriate and clear conditions.

6-6 Contract compliance

We will always comply with the contract contents in the service development and delivery, and strive to achieve the promised SLA with the client.In addition, we do not perform tampering or false reporting of KPIs.

6-7 Client and business partner relations (1) Rule compliance

In addition to establishing rules necessary for business with clients and partner companies, the Company will establish common rules and checks, and do our best to comply with them for the benefit of both sides.

6-8 Client and business partner relations (2) Suggestions for improvement, recommendations

The Company recommends the best ways to improve customer relations to their clients.

6-9 Client and customer relations (3) Communication

Executives and employees build a mutually respecting relationship by always dealing with clients and partner companies in a regular manner during working hours and outside working hours.

6-10 Protection of personal information

In accordance with the Act on the Protection of Personal Information, the Company pays close attention to the entire process of information collection, use, storage and disposal, and improve and continuously maintain the best condition of the management system.

6-11 Protecting confidential information

The Company protects the information considered to be company secrets, with clients, their customers and partners having no way to acquire or use the confidential information in an unauthorized or unfair manner.

Executives and employees must not refer any information they know about the Company, its clients and their customers, partners, or anything related to the business outside work, and prohibit writing of such information on the Internet.

Even if it is information that can be generally known, findings that affect customers and companies without the company’s permission may not be disclosed or announced to the media.

6-12 Protecting your intellectual property rights

The Company recognizes that services such as the tools, applications, manuals, and products that we have developed to perform our work are important intellectual property, and we will hold and protect our intellectual property rights accordingly.

6-13 Protection of intellectual property rights of third parties

We respect the intellectual property rights of third parties and will not violate them.

6-14 Timely and appropriate recording of accounting records

By establishing a business process incorporating multiple confirmations and approvals, we will create fair accounting and appropriate accounting records.

6-15 Business continuity at the time of disaster

In the event of a disaster, the Company will consult with clients and partner companies in advance on how to respond according to the situation. During a disaster, we will do our best to keep the business running while maintaining close communication.

6-16 Importance of "ID Card" and "PC"

Our executives and employees reaffirm the importance of ID cards and PCs, and comply with the handling rules and prevent loss.

7. Create an environment in which employees can work comfortably

7-1 Compliance with labor-related laws and regulations

The Company complies with labor-related laws and regulations such as the Labor Standards Act, and strives to maintain and improve a comfortable working environment for employees.

7-2 Building a safe work environment

The Company will comply with various laws and regulations such as the Fire Service Act and the Industrial Safety and Health Act, and strive to maintain and improve a safe and comfortable working environment.

7-3 Compliance with internal rules such as employment rules

The Company creates work rules and rules in accordance with various laws and regulations, encouraging employees to be aware and thoroughly comply to them.

7-4 Safety confirmation at the time of disaster

The Company will promptly confirm the safety of employees and prepare a system for evacuation in case a disaster occurs.

7-5 Prohibition of child labor and forced labor

The Company does not have children under the minimum working age set in the country or region, and does not force labor against the will of the workers.

7-6 Prohibition of political and religious activities

The Company does not conduct any political or religious activities in our business activities for our clients and partner companies. The Company also does not solicit or sell goods and/or services unrelated to our business.

7-7 Respect for diversity

We strive to create an open workplace where employees with diverse values can exchange ideas with each other, respect each other, and work comfortably.

In addition, the Company eliminates all discrimination due to irrational reasons based on “sex, age, hobbies, educational background, nationality, origin, race, religion, disability, sexual orientation, etc.”, and irrational treatment in recruitment, employment, promotion, etc.

7-8 Human Resource Development, Career Development Initiatives

The Company will develop a system to objectively evaluate the ability of employees, create a mechanism for capacity development, provide opportunities for motivated and capable employees to be fully active, and support human resource and career development.

7-9 Communication in the workplace

Employees will always consult with the manager when they get lost in decision-making, and the manager will always do their best to create a work environment that makes consultations easy, and will work as an organization to solve the issues.

7-10 Prohibition of various forms of harassment such as power harassment and sexual harassment

Executives and employees shall respect each other’s human rights. Hurting the dignity of others through sexual speech (sexual harassment), harassment against a background of position and authority (power harrassment), and the like disturbs the sound environment of the workplace. The Company does not do any acts that disturb the conduct of business, and does not act in any way that impedes business operations or cause misunderstandings.

7-11 Promotion of work-life balance

In order to promote the work-life balance of our employees, we will establish a personnel and treatment system that enables diverse working styles. Managers are careful not to put an excessive burden on employees by supporting planned business operations, preventing overtime work, and encouraging employees to have vacations.

7-12 Compliance with social norms and manners

Executives and employees maintain the public order and morality of society, and as members of the society and the Company, we will always take responsibility and will not act unfairly against colleagues and fellow members.

7-13 Preservation of company assets

Executives and employees are managed in accordance with the rules established by the Company, so as not to damage the company assets managed by individuals or departments.

7-14 Proper use of company assets

Executives and employees use the Company’s personal or departmental assets for legitimate business purposes only, not for personal diversion or fraudulent purposes.

7-15 Prohibition of conflict of interest transactions

Executives and employees do not act in a competitive way with our business, or conduct business with the Company involving themselves and/or their relatives, or at the expense of our profits and gain.

7-16 About insider trading

Executives and employees cannot obtain important information about the Company or our business partners for the purpose of personal benefit, but rather strive to prevent insider trading.

In addition, we do not condone insider trading even if performed through third parties, or if no profit is made.

7-17 Media Relations

The executives and employees should follow the instructions of the public relations department when dealing with various media. The Company does not contact the media without obtaining the approval of the public relations department, and will not make remarks representing or likely to be considered representative of the Company.

In addition, when an employee has an opinion on the Company’s Management Policy, business, personnel organization, management system, etc., they will submit an opinion in a timely and appropriate manner according to the method and route determined by the Company. Defamation on the Internet and the like will not do.

8. Healthy relationship with the government and administration

8-1 Political and administrative relations

The Company maintains sound and transparent political and administrative relations, and do not engage in bribery, illegal giving of profits, excessive entertainment or gift-giving, or any act of aggression or suspicion.

9. Dealing with antisocial forces

9-1 Cut off relations with antisocial forces and organizations

The Company deals with antisocial forces and organizations that threaten social order and safety with a resolute attitude and do not have any form of relations, including business relationships.

10. Code of conduct compliance

10-1 Management top attitude

The top executives realize that their sincere attitude is the basis of legal compliance and establishment of corporate ethics, that they will take the lead and thoroughly implement them in the Company, and strive to fulfill corporate social responsibility.

10-2 Establishment of a compliance system

Top management builds a system to promote corporate ethics and risk management, and leads the system to function effectively. In addition, the Company will maintain a system for reports, communication, and consultation to obtain various types of information quickly and appropriately, and will continuously improve corporate behavior.

10-3 Enforcement of code of conduct

The top management conducts education and training on complete awareness in complying with the code of conduct, and promotes exhaustive corporate ethics by continuously improving the content. In addition, the Company will strive to obtain the cooperation necessary to comply with this standard, not only for executives and employees but also for partner companies.

10-4 Measures when there is a risk of being violated

The top management conducts education and training on complete awareness in complying with the code of conduct, and promotes exhaustive corporate ethics by continuously improving the content. In addition, the Company will strive to obtain the cooperation necessary to comply with this standard, not only for executives and employees but also for partner companies.

10-5 Punishment in case of violation

We will strictly dismiss the offender, executives, and/or seniors who are responsible for their management and supervision in accordance with our internal rules for violating or infringing our internal rules on punishment.

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