Compliance
OPTEX Group Code of Conduct
The OPTEX Group Code of Conduct was adopted in 2003, clarifying acceptable conduct for all officers and employees, and has formed the basis of compliance promotion activities.
With the transition to a holding company stance on January 1, 2017, the Code of Conduct was revised to apply to OPTEX and all consolidated subsidiaries, cumulatively referred to as the Group. All Group employees have been informed of the Code of Conduct, and initiatives implemented to promote compliance.
The goal, encompassing compliance with laws and government regulations, corporate regulations, and social mores, and fairness and sincerity in business interactions by all officers and employees, is to ensure that we earn and keep the trust of society, and create a corporate culture to serve as a model for the industry.
It is crucial that each and every one of us remain keenly aware of these goals, and ensure that our actions are in accordance with the Code of Conduct.

January 2017

Section 1 General Provisions
1. Purpose for enactment
A corporation should not exist to pursue profit alone; rather it must also justify the reason for its existence in society and create something valuable for that society through its efforts. Recently there has been series of corporate scandals, which only serve to emphasize the need for proper corporate action based on this philosophy.
It is therefore necessary to clearly define a code of conduct based on social values in order to maintain social order. Each individual must understand this code at a high enough level such that it guides all their actions.
Since its founding, this company has emphasized social value as expressed in our Management Philosophy, which places fulfillment of social responsibility at the core of all management goals.
The purpose of this OPTEX Group Code of Conduct is to enact these principles in daily work activities by enumerating specific rules and goals which must be followed in various work contexts. Using this Code of Conduct as a basis for daily action in a variety of situations will create trust for the OPTEX Group and allow it to become a model corporate citizen.
2. Scope of application
The code of conduct described in this document applies to all officers and employees (including but not limited to full employees, contract employees, part-time workers, advisors, and temp workers) employed by the OPTEX Group*, hereafter referred to as “we” or “officers and employees.”
All companies within the OPTEX Group shall adopt this code of conduct as their own and take appropriate measures to ensure that their officers and employees understand it fully.
However, changes or additions may be implemented to the extent that they do not contradict the original code if necessitated by national or regional laws, social customs, or business conditions.
*Refers to OPTEX GROUP CO., LTD. as well as all affiliated subsidiaries and their respective affiliated subsidiaries.
3. Basic stance
Our highest goal is to continuously improve corporate value while earning the trust of all stakeholders, including customers, partners, stockholders and other investors, and local communities. In order to realize this goal, all corporate activities shall be made compliant with relevant laws, this code of conduct, and internal regulations, while a spirit of integrity, honesty, and fairness shall govern the social awareness that guides all actions.
Section 2 Offering safe and highly reliable products and services
1. Research and development
We shall create new products and business activities through invention, discovery, and continuous improvement based on a spirit of bold creativity and ceaseless diligence. These shall improve the quality of people’s lives through enhancing safety, peace of mind, and comfort.
2. Sales
Our motto is “customer first,” and our goal is customer satisfaction and trust through offering services and products that are excel in both safety and quality.
We also strive to contribute to society through engaging in fair and free competition. To realize this goal we never forget gratitude in dealings with our customers, following social ethics and applicable laws while engaging in fair sales activities, always aware that every individual is a representative of the company.
3. Product safety
Our highest priority is maximizing product safety and strive towards that goal in all work processes so that our products and services may be worthy of customer trust. We will also anticipate actual customer usage situations, prevent accidents beforehand, design safety into our products, and take all appropriate steps to aid our customers in using our products correctly, from easily understood markings on products to fully informative manuals.
Section 3 Integrity and Fairness in All Activities
1. Free competition and fair trade
(1) Fair competition
We recognize the importance of free competition in the marketplace, and will not engage in inappropriate restrictive or unfair trading practices which interfere with fair competition.
(2) Fair sales practices
We shall place the highest priority on fair sales practices based on social ethics and applicable laws, even in the most competitive situations. We shall not pursue profit at the expense of abandoning social ethics or breaking laws, including offering bribes, engaging in fixed bidding, participating in cartels to restrict competition, restricting sales prices for customers or partners, or making fictitious business transactions.
(3) Fair procurement
We shall observe healthy business practices and contracts in procuring various goods and services as part of our business activities, eliminating all bribery and payoffs while maintaining equitable and fair dealings.
2. Observing import/export laws and regulations
We shall observe all applicable countries’ import/export-related laws and regulations when importing or exporting goods and services or disclosing technical information about these (including software technical instruction)..
3. Restrictions on entertainment and gifts
(1) Relations with customers and partners
We shall engage in entertainment as well as giving and receiving gifts with customers and partners only to the extent that these do not violate healthy business practices and social norms.
(2) Constructing healthy relationships with politicians and governments
We shall not engage in any entertainment, gift-giving, or other actions with no rational basis with domestic or foreign government officials or public servants which may be construed as inappropriate payoffs or favors.
(3) Stockholder relations
We strive to always maintain healthy, transparent relationships with stockholders. Specifically, we shall not engage in entertainment, gift-giving, or otherwise offer economic benefit to stockholders in relation to their exercise of stockholder rights.
(4) Antisocial forces
We shall refuse all relations with organized crime or any other antisocial forces or organizations which threaten social order and safety, and shall steadfastly resist these forces along with society as a whole. We shall not as organizations or individuals perform any action which may aid these antisocial forces or organizations.
4. Accuracy of financial reporting
We shall perform accurate accounting and tax preparations in full accordance with applicable corporate accounting laws and standards. Also, we shall implement strict internal controls to make improvements in accounting accuracy and the health of financial affairs.
5. Workplace environment
In order to create a pleasant and safe workplace environment, we shall observe all labor-related laws as well as continuously promote improvements in workplace environment and health and safety.
Section 4 Ethical Conduct
1. Individual actions which conflict with company benefit
Individual actions which conflict with or may possibly conflict with company benefit are forbidden.
2. Political and religious activities
Political activities within the company are forbidden unless permission has been explicitly granted. While private religious activities such as prayer during breaks are allowed, other religious activities such as sermons or proselytizing are forbidden without explicit permission.
3. Corporate information management
(1) Protecting confidential information
We are always aware of the proprietary nature of all classified information related to the OPTEX Group and our customers and partners. We shall take all appropriate measures to manage this information responsibly, including preventing leaks and inappropriate uses.
(2) Protecting private information
We shall endeavor to improve information management systems to control customer information, partner information and private information related to employees, as well as strictly follow the Private Information Protection law and other related laws.
(3) Information disclosure and public relations
We shall perform legally mandated information disclosure to all stakeholders (customers, partners, shareholders and investors, local communities, etc.) as well as fulfill explanatory duties by actively and accurately disseminating socially relevant information such as managerial policies, business activities, and corporate social responsibility (CSR) activities.
(4) Insider trading
We forbid use of not yet publicly available information to engage in insider trading or otherwise confer payoffs or favors to third parties, thus negatively affecting shareholder or investor value.
4.Protecting corporate assets
(1) Inappropriate use of corporate assets
We forbid infringement upon either tangible or intangible corporate assets for personal benefit or other inappropriate uses, and shall manage and use corporate assets in appropriate ways only.
(2) Protection and use of intellectual property
We recognize intellectual property rights resulting from R&D or other activities as the lifeline of our business, and shall both leverage and protect these actively. Further, we respect the intellectual property rights of others, and shall not intentionally infringe upon these rights.
5. Respecting fundamental human rights
(1) Human rights
We respect the human rights of all individuals, and shall not discriminate in terms of labor conditions, language, or action on the basis of gender, age, nationality, race, ethnicity, beliefs, religion, social status, or physical disability.
(2) Prohibition on harassment
We shall educate employees to prevent all forms of harassment, including the usage of language which does not respect the personal dignity of people of other genders, occupations, status, or other characteristics, such as power harassment, sexual harassment, and maternity harassment.
a) Power harassment refers to the use of position within the organization, interpersonal relationships, or other factors to infringe on the personal rights and dignity of other employees to an extent beyond the reasonable limits of employment, including teasing and abuse.
b) Sexual harassment cannot be permitted in the workplace, because it can severely interfere with normal operations. Improper verbal advances can make the workplace environment unpleasant for the harassed party and prevent them from working to full capacity. Sexual harassment can result in employee punishments such as reduction in salary or rank, or even termination.
c) Maternity harassment refers to inappropriate treatment or termination of employees requesting maternity or childcare leave. The above definitions of harassment all include similar actions which are not based on the authority of the harassing party, and other actions which degrade the workplace environment and infringe the personal rights and dignity of others.
(3) Privacy
We respect the individual’s right to privacy, and shall not without express consent divulges any information gained through workplace activities about the private life of any individual.
Section 5 Social Responsibilities
1. Environmental protection and preservation
(1) Social responsibility towards the environment
We recognize that protection of the environment is a corporate social responsibility, and to do so we will engage in continuous environmental improvements and enhancements while observing all environmental treaties, laws, and international standards. We will also work towards improving awareness among officers and employees through promotion of environmental management systems.
(2) Environmental preservation as a part of business activities
We recognize that environmental protection is one of the most important goals of corporate management, and work towards improving harmony with the environment in all areas of corporate activity. The philosophy of “reduce, reuse, and recycle” forms the basis for these efforts, which also incorporate maximizing usage of resources, improving energy efficiency, and reducing industrial waste over all our activities.
2. Communicating with local communities
We recognize ourselves as members of our local communities, with whom we strive to develop together with in a harmonious way.
3. Social contributions
In addition to contributing to society through our business activities themselves, as corporate citizens we actively support and engage in social action aimed at developing and enriching society.