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Cosmo Oil Group Code of Conduct

Chapter 
1 Live up to customer expectations concerning reliability and satisfaction

As a company that plays an important role in supplying energy, we develop products and services that meet customer expectations concerning reliability and satisfaction, and deliver them to customers in a stable manner.

1.We strive to deliver stable energy supplies

(1) Stable energy supplies

• Approach

We strive to ensure stable energy supplies as we are involved in supplying energy and it is our responsibility.

2.We develop and provide products and services that customers can rely on

(1) Basic approach to customers

• Basic approach

We strive to interact with customers responsibly and in good faith to ensure that they feel comfortable and secure, and gain confidence in our work.

• Cooperate with trade partners

We strive to ensure that the trade partners who handle our products and services understand and respect the spirit of our Code of Conduct and comply with it so that our trade partners may also feel confident in those products and services.

(2) Maintain quality and secure safety of products and services

• Maintain quality and secure safety

We strive to maintain the quality and secure the safety of our products and services at all stages of our business activities. We do not provide products or services that do not comply with the stipulated quality and safety standards.

• Approach to technological innovation and enhancing expertise and skills

We strive to promote technological innovation and enhance knowledge and ability as a means of maintaining the quality and securing the safety of our products and services.

(3) Develop and provide products and services that satisfy customers

• Reflect feedback from customers

We accept feedback concerning products and services from customers sincerely, and strive to develop and improve products and services that can satisfy them.

• Improve customer support systems

We strive to provide customers with responsible support and after service by promoting improvements in customer support systems such as the Cosmo Oil Customer Center.

(4) Honest responses to customers

• Appropriate disclosure and explanations of product information

We disclose and explain information pertaining to products and services (including warnings about their hazardous nature, erroneous use and other information concerning safety) as appropriate so that customers can use our products and services safely and with assurance.

• Fair dealings with customers

We endeavor to deal fairly with customers by ensuring that we never provide fabricated, falsified or inaccurate data or stipulate unreasonable conditions.

• Response to product accidents and problems

In the event that product- or service-related accidents or problems occur, we make every effort to adopt speedy, appropriate responses that place top priority on ensuring customer safety, averting danger and preventing any damage from spreading.

Chapter 2  We aspire to become a safe, accident-free company

We see safe operations and stable supplies as top-priority issues, and work to ensure safety and harmonious coexistence with society in all our business activities.

1.We strive rigorously to prevent accidents and industrial injuries

(1) Initiatives aimed at zero accidents and industrial injuries

• Approach

We work to prevent accidents and industrial injuries by observing safety-related laws and promoting voluntary safety management activities with cooperative companies.

2.We handle accidents and disasters responsibly should they happen

(1) We respond rapid and appropriately to accidents and disasters

• Approach

We have established emergency responses in readiness for accidents and disasters. Giving respect for human life absolute precedence, we have also established measures to minimize damage in emergencies by communicating (notifying, reporting) and cooperating rapidly and appropriately with relevant agencies (administrative agencies, related departments in the company, cooperative companies, etc.).

3.We work to improve safety education

(1) Provide safety education

• Approach

We engage in rigorous education and training to ensure safety. We also implement educational activities aimed at cooperative companies, offering them necessary advice and guidance.

Chapter 3  We value people

We respect individuals and their fundamental human rights, and strive to create a workplace environment where individual employees can demonstrate their abilities to the full.

1.We respect each individual

(1) Respect fundamental human rights

• Basic approach

We respect individuals and their fundamental human rights, and neither engage in nor countenance acts that infringe on human rights. We also support the principles and spirit of the Universal Declaration of Human Rights.

• Prohibit discrimination

We neither discriminate nor condone discrimination on the grounds of birth, nationality, race, beliefs, religion, sex, age or disability.

• Prohibit forced labor

We neither force people to work against their wishes, nor condone it.

• Prohibit child labor

We do not condone child labor, or employ children.

• Respect the lands and rights of indigenous peoples

We support the principles and spirit of the United Nations Declaration on the Rights of Indigenous Peoples, and respect the land and other rights of indigenous peoples.

• Approach to business in countries with human rights issues

We make decisions on starting and continuing businesses in countries with serious human rights issues after taking into consideration whether we can act in accordance with this Code of Conduct and have a beneficial, long-term impact on the countries in question.

• Security measures that respect human rights

We support international standards concerning the use of weapons such as the UN's Code of Conduct for Law Enforcement Officials, and do not adopt security measures that infringe on human rights.

2.We work to create bright workplaces where employees can work comfortably

(1) Operate a fair and equitable personnel system

• Ensure assessments are fair and equitable and prohibit discrimination, etc.

In the areas of personnel management, treatment and employment, we make fair and equitable assessments based on aptitude and abilities, and do not discriminate or treat unfairly.

• Implement fair and equitable hiring activities

We engage in fair and equitable hiring activities that are based solely on aptitude and abilities and respect the fundamental human rights of job applicants.

(2) Create a comfortable workplace that is conducive to work

• Improve operational efficiency and manage working hours appropriately

We strive to improve operational efficiency and manage working hours appropriately.

• Endeavor to ensure a proper work/life balance

We respect the values and life philosophies of individual employees and strive to promote their endeavors to achieve harmony between work and life (work/life balance) and realize comfortable lifestyles that allow them to live the lives they aspire to.

• Respect diversity

We respect the individuality of all employees, and strive to create diversity in the workplace to allow them to enhance and demonstrate their abilities.

• Ensure proper health care

We work to promote employee health care and to maintain and enhance their physical and mental wellbeing.

• Prohibit sexual harassment, etc.

We neither condone nor engage in sexual harassment, abuse of authority or any other kind of harassment.

• Ensure stable employment

We work to support schemes designed to ensure stable employment.

(3) Create a safe workplace environment

• Improve the workplace environment

We strive to improve the workplace environment to make it safer and easier to work in. We also strive to keep the workplace clean, tidy and in order.

• Ensure employee safety and rigorous risk management

We work to ensure the safety of employees, who are a vital asset of the company, and to enforce rigorous risk management for that purpose.

(4) Foster human resources

• Foster human resources

We endeavor to foster human resources through programs that take employees' self-realization into consideration.

• Ensure technological continuity

We constantly endeavor to improve ourselves in order to enhance our abilities and skills. We also groom our successors to ensure that the technology and know-how that we have built up to date through experience and effort are passed on to the next generation of employees.

(5) Healthy employee/management relations

• Build healthy employee/management relations

We respect the right to organize and the right to collective bargaining and other fundamental legal rights of labor, and are working to build healthy, transparent employee/management relations.

Chapter 4  We take care of the global environmente

We believe the resolution of global warming and other problems relating to the global environment are extremely important issues, and work faithfully, proactively and continuously on environmental preservation measures and activities.

1.We do what we can to preserve the global environment

(1) Initiatives to cope with global warming

• Approach

We have adopted measures to cope with global warming in order to curb greenhouse gas emissions and conserve energy and resources at all stages of our business activities.

(2) Minimize environmental impact

• Approach

We work to minimize the environmental impact by cutting emissions of pollutants at all stages of our business activities.

2.We act after fully considering the global environment

(1) Be environmentally conscious in business expansion and technological development

• Approach

We develop products with a smaller environmental impact, proactively develop technologies for new energy businesses that help preserve the environment, and promote technology transfers relating to energy conservation and environmental protection.

(2) Approach to environmental contribution activities

• Approach

We engage in educational activities pertaining to environmental issues through proactive involvement in global environmental preservation activities based on the theme of preventing global warming, and support environmental education aimed at new generations of children.

Chapter 5  We value communications with society

We value communications with society, and proactively and independently contribute to the development of regional communities. We also use wide-ranging publicity activities and information disclosure to promote better understanding of our company and its activities.

1.We work for the development of the community

(1) Participate in social contribution activities as a corporate citizens

• Participate in social contribution activities

As good corporate citizens, we proactively engage in social contribution activities in order to contribute to the realization and sustainable development of a prosperous society.

(2) Promote activities that respect culture and customs

• Respect the culture and customs of the host country/region

In our overseas activities, we comply with the laws, regulations and social codes of the countries and regions in question as a matter of course, respect their culture, customs and history, and strive to contribute to their development.

• Assess impact on regional communities

We always study and assess the impact of our activities on the societies of other countries and regions overseas before we engage in large-scale investments or business developments there.

• Develop human resources belonging to the regional community

Wherever we are active, be it in Japan or overseas, we endeavor to foster human resources from the countries and regions in question.

2.We strive to keep people informed

(1) Honest publicity activities

• Approach

Based on the principle of transparency in management, we engage in honest, proactive publicity and communications activities to promote better understanding of our business activities, corporate vision and management policies. We also endeavor to faithfully reflect in our business activities the feedback we receive through our communications activities.

(2) Appropriate information disclosure

• Disclose information in a timely and appropriate manner

We disclose in a timely and appropriate manner any corporate information that should be disclosed, including information concerning our financial position, our management, accidents and safety matters.

• Disclose accurate information

We strive to ensure that the content of the information we must disclose is accurate, fair and adequate. We do not cover up or falsify information that should be disclosed.

(3) Follow appropriate procedures for accounting and preparing legal documents

• Appropriate accounting procedures

We use appropriate accounting procedures. We record accounting information appropriately and never use improper accounting procedures.

• Follow appropriate procedures for preparing legal documents

We prepare accounting documents, financial statements and other legal documents in an appropriate manner.

Chapter 6  We strive to maintain our position as an honest company

We are determined to remain faithful to society and to act as responsible and sensible members of society.

1.We engage in sensible activities as members of society

(1) Enforce corporate ethics thoroughly

• Basic approach

We comply with laws and regulations, in-house regulations and social codes, and act fairly and honestly as members of society.

• Carry out thorough training in corporate ethics

We carry out thorough education and training in corporate ethics.

• Operate a Corporate Ethics Consultation Helpline in an appropriate manner

We have established the Cosmo Oil Group Corporate Ethics Consultation Helpline and operate it in an appropriate manner as a scheme for reporting and consulting on issues and cases involving corporate ethics.

(2) Draw a clear line between business and private matters

• Basic approach

We do not use the positions or rights we have in the company to secure personal or other improper benefits.

• Prohibit conflicts of interest with the company

We do not engage in transactions that compete with the company, transactions with the company's competitors, or other acts that conflict with the company's interests. In addition, we do not assume the office of director, etc., in other companies, etc., except as part of the company's business.

2.We treat company property with care

(1) Manage and use company property properly

• Use company property correctly and efficiently

We use assets, intellectual property, information and other company property appropriately and efficiently. We use company property for business purposes only, not for personal or other improper purposes.

• Manage company property properly

We manage company property properly to prevent it from being damaged, lost or stolen.

(2) Protect and respect intellectual property

• Preserve and manage intellectual property properly, and use it appropriately and effectively

We recognize that the intellectual property held by the company is an important company asset, and make effective and appropriate use of it while preserving and managing the rights in question properly.

• Respect the intellectual property of others

We respect the intellectual properties of others, and do not engage in acts that infringe on their rights.

3.We are honest in our transactions

(1) Honest transactions

• Share prosperity with trade partners

In addition to respecting our trade partners’ position as partners and promoting mutual prosperity, we strive to ensure that they implement this Code of Conduct together with us.

• Select trade partners fairly and equitably

We select our trade partners on the basis of fair and equitable assessments. We also endeavor to deal with trade partners who act in accordance with this Code of Conduct.

(2) Realize free and fair transactions

• Free and fair transactions

We engage in free and fair transactions. We do not use private monopolies, cartels or unfair business practices in transactions

(3) Appropriate purchasing and subcontracting operations

• Proper dealings with trade partners, etc.

In our transactions with trade partners and subcontractors, etc., we do not engage in illegal acts such as refusal to accept, payment delays or the imposition of unreasonable terms of business.

(4) Restrictions on entertainment and gifts

• Restrictions on entertainment and gifts

We do not give or receive entertainment or gifts that deviate from social norms or internationally accepted conventions. Moreover, we do not give or receive inappropriate entertainment or gifts for the purpose of providing personal or other improper benefits.

(5) Build highly transparent relationships with government and administrative agencies

• Transparent and healthy relationships with government and administrative agencies

We maintain moderate, transparent and healthy relationships with government and administrative agencies.

• Prohibit entertainment of, and gifts to, civil servants

We do not entertain or exchange gifts with civil servants or equivalent persons (including former civil servants).

• Prohibit improper monetary donations and payoffs, etc. to politicians and political organizations

We do not make improper monetary donations, payoffs or benefits to politicians (including political candidates) or political organizations.

• Prohibit bribery

Whether at home or abroad, we do not engage in bribery, or promise or request bribes.

(6) Non-participation in antisocial behavior

• Stance toward antisocial forces

We have absolute no relationships with antisocial forces or groups who may threaten social order or safety, and face up to them with a resolute attitude.

• Prohibit payoffs

We do not make payoffs in connection with the exercising of stockholder's rights.

(7) Import/export procedures

• Proper customs, etc., procedures

We follow proper customs procedures for exports and imports.

• Improve security export control system

We are improving our security export control system and control restricted cargoes rigorously in order to maintain international peace and security.

4.We handle information properly

(1) Handle information properly

• Acquire information in an appropriate manner

We acquire all information learned in the course of business within or outside the company in an appropriate manner. We do not acquire information by improper means, or without the permission of a person with legitimate authority. We do not acquire information that has or may have been obtained improperly.

• Use information in an appropriate manner

We use information in an appropriate manner. We use information for business purposes only, not for personal or other improper purposes. In particular, we use personal information (including the personal information of employees; the same applies hereinafter), and confidential company information for business purposes only and with the permission of the person(s) in question or the company, as applicable. We do not disclose personal or confidential information without the permission of the person in question or the company, as applicable.

• Manage information in an appropriate manner

We manage information in an appropriate manner. In particular, we have adopted appropriate measures to prevent personal or confidential company information from being leaked, destroyed or damaged, and keep it secure through more rigorous management.

• Use information systems in an appropriate manner

We use the company's information systems in an appropriate manner. We use information systems for business purposes only, not for personal or other improper purposes.

• Maintain information system security

We protect information by striving to assess risks to information systems, the status of countermeasures and the latest technologies, and adopting necessary security measures to prevent unauthorized access to such systems.

(2) Prohibit insider trading

• Prohibit unfair stock trading, etc.

We do not engage in stock purchases based on important undisclosed internal information concerning the company or other companies (insider trading).

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