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Code of Conduct

Foreword

As an enterprise that provides entertainment-rich, top-quality pachinko and pachislot machines and related services in the spirit of the corporate motto of “ingenuity,” SANKYO Co., Ltd. (the “Company”) shall adhere to high ethical standards to fulfill its social responsibilities. The Company’s Code of Conduct is based on international human rights standards and guidelines for corporate behavior, and serves as a guide to ensure that every employee acts with integrity.

1.Basic Policy

The Company respects the following international codes of conduct and guidelines and shall strive to conduct itself ethically.
 ●International Bill of Human Rights*1
 ●ILO Fundamental Conventions*2
 ●Guiding Principles on Business and Human Rights*3

*1:A collective term for the Universal Declaration of Human Rights; the two International Covenants on Human Rights (the International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and Political Rights); and the First and Second Optional Protocols to the International Covenant on Civil and Political Rights.
*2: Convention that sets out in concrete terms the principles relating to fundamental rights at work adopted by the International Labour Organization (ILO)
*3:An international document on respecting human rights in corporate activities, approved by the United Nations Human Rights Council in 2011.

Respect for Human Rights

The Company respects the human rights of all employees, business partners, customers, and local communities. The Company does not tolerate harassment, forced labor, child labor, or discrimination based on race, religion, gender, age, sexual orientation, physical characteristics, nationality, or any other attribute. Furthermore, if the Company becomes involved in any adverse human rights impacts, it shall address those impacts and endeavor to remedy them.

Legal Compliance

The Company complies with the laws and regulations of all countries and regions in which we conduct our business activities. The Company shall also adhere to industry guidelines and international norms and promote ethical behavior.

2.Together with Employees

Respect and Fairness

All employees shall treat one another with respect and maintain a fair working environment without discrimination. The Company respects diverse values and privacy and shall strive to create a rewarding workplace for all employees, in its efforts to achieve sustainable growth of both organization and individuals.
The Company shall adhere to minimum wages set by the relevant laws and regulations and shall pay its employees overtime pay and other benefits, including statutory benefits. It shall not reduce wages in a manner that violates labor laws or regulations. The Company shall also provide its employees with fair wages that are sufficient to support a decent standard of living, ensuring access to a culturally fulfilling lifestyle.

Ensuring safety of working environment

Considering the safety and health of its employees, the Company shall create a working environment where they can work with peace of mind. The Company shall also strive to ensure the safety of its employees and local communities by taking appropriate measures according to the risks involved, in order to prevent the occurrence of occupational accidents and illnesses.

Guarantee of workers' rights

In accordance with applicable laws and customs, the Company respects employees’ freedom of association and their rights to organize, to engage in collective bargaining, and to take collective action as fundamental labor rights. The Company guarantees employees the freedom to form, join, or refrain from joining labor unions, enabling workers to engage in labor-management consultations on matters such as working conditions and wage levels.

Compliance

Employees shall comply with company policies as well as all applicable laws and regulations, endeavoring to prevent fraud and corruption. In all circumstances, they shall exercise ethical judgment and act with integrity.

Whistleblowing system

The Company shall establish a whistleblowing system to appropriately identify and respond to the risk of human rights violations, such as violations of laws and regulations, etc., harassment, discrimination, and inappropriate working conditions. The Company shall also ensure the anonymity of whistleblowers and eliminate any disadvantageous treatment such as retaliation against whistleblowers.

3.Together with Customers and Business Partners

Ensuring quality and safety of products

The Company shall ensure quality standards stipulated by relevant laws and regulations, and, as a leading company in the pachinko and pachislot industry, develop and provide high-quality, safe, and reliable products and services that will earn the satisfaction and trust of customers.

Fair Trade

The Company shall engage in fair, transparent, and open competition, engaging in appropriate transactions with its business partners, and building sound, professional relationships with them. The Company shall not engage in any form of bribery or improper profiteering and shall promote fair competition.

Protection of information and intellectual property

The Company shall safeguard customers’ personal information and all other confidential information, ensuring such information is neither used nor disclosed without permission. The Company shall safeguard its customers’ trust by strengthening information security to prevent information leaks due to cyber-attacks, etc.
The Company respects intellectual property rights and shall not infringe on the rights of third parties. It shall appropriately manage and protect intellectual property belonging to the Company.

Supply Chain Responsibility

The Company expects its business partners to act ethically in accordance with the Company’s Code of Conduct.

4.Together with Local Communities

Contribution to Local Communities

The Company shall strive to coexist with local residents through its business practices and contribute to the development of local communities. As a good corporate citizen, the Company shall do its utmost to coexist harmoniously with local communities and deepen relationships of trust.

Environmental impact reduction activities

The Company is committed to protecting the environment and contributing to the realization of a sustainable society. Considering the environmental impact of its business, the Company shall promote initiatives to minimize this impact, such as waste reduction, the use of renewable energy, and the proper management of chemical substances, in cooperation with the local communities.

5.Compliance with the Code of Conduct and Continuous Improvement

Audit and Evaluation

The Company shall periodically conduct audits and evaluations to assess compliance with the Code of Conduct. If problems are identified, remedial measures shall be implemented promptly.

Education and Awareness-raising

The Company shall inform its employees of the importance and content of the Code of Conduct and promote awareness-raising activities to ensure that all employees understand and adhere to the Code of Conduct.

Review and Improvement

The Company shall periodically review the Code of Conduct and revise it as necessary in light of changes in social conditions and the business environment. The Company shall continually improve the Code of Conduct to ensure sustainable corporate development and fulfillment of its social responsibility.

Conclusion

Through behavior with integrity based on the Code of Conduct, the Company endeavors to earn the trust of all stakeholders and contribute to realization of a sustainable society. Every employee pledges to abide by this Code of Conduct and to ensure fulfilment of the Company’s corporate responsibilities.

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