Introduction

　This Code of Conduct outlines the values, ethics, and actions that all individuals working at MAX Group (hereinafter referred to as “we”) should share.
By adhering to this Code of Conduct, we aim for our own growth and the sustainable development of the MAX Group, while fulfilling our corporate social responsibilities and meeting the trust and expectations of our stakeholders.

1. Supplying Quality Products and Services

　We will serve society and contribute to culture by supplying quality products and services to customers worldwide.

2. Respect for Human Rights

　We will recognize respect for human rights as a fundamental standard of conduct required of all companies and eliminate all forms of discrimination and harassment.

3. Preservation of the Global Environment

　We will give utmost consideration to preserving the global environment and contribute to building a sustainable society where people and nature coexist.

4. Promotion of Fair and Transparent Business Activities

　We will respect internationally recognized norms, comply with domestic and international laws and regulations as well as internal rules, thoroughly implement corporate ethics, and promote honest business activities.

5. Promoting Communications with Society

　We will promote communications with society by disclosing corporate information in a timely and appropriate manner for the enhancement of sustainable corporate value.

6. Responsible Actions

　When incidents occur that violate this Code of Conduct, we will promptly and accurately disclose information, investigate the cause, and implement measures to prevent recurrence. We will also strive to ensure that stakeholders, including our business partners, understand the purpose of this Code of Conduct.

1. Supplying Quality Products and Services

　1-1. We will practice creating things and experiences that exceed our customers’ expectations and continue to provide innovative, safe, and high-quality products and services.

　1-2. We will listen to our customers’ voices and reflect their feedback in the development and improvement of better products and services.

　1-3. We will advance our business through the creation of intellectual property without infringing on the intellectual property rights of third parties.

　1-4. In the event of any issues arising with our products or services, we will address them promptly, appropriately, and fairly, and implement measures to prevent recurrence.

　1-5. We will strive for personal growth and organizational vitality not only through individual self-development but also through mutual learning and collaboration.

2. Respect for Human Rights

　2-1. We will continue to study the United Nations’ “Guiding Principles on Business and Human Rights” and “Universal Declaration of Human Rights,” and other internationally recognized human rights standards and address various human rights issues.

　2-2. We will comply with the MAX Group Human Rights Policy.

　2-3. We will establish a human rights due diligence framework to identify adverse impacts on human rights and strive to prevent and mitigate them.

　2-4. Based on the MAX Group Sustainability Guidelines for Business Partners, we will work with our suppliers to build responsible supply chains, including prohibiting the procurement of minerals that may be associated with human rights violations.

　2-5. We will respect the dignity, rights, and diversity of all individuals, refrain from unfair discrimination, eliminate harassment, child labor, forced labor, etc., manage appropriate working hours, foster a comfortable workplace environment with consideration for safety and health, respect the freedom of association and the right to collective bargaining, and cultivate an open corporate culture.

3. Preservation of the Global Environment

　3-1. We will pursue the reduction of environmental impact across society throughout the entire lifecycle of our products and services, from development, manufacturing, sales, and transportation, to use and disposal.

　3-2. We will work to reduce greenhouse gas emissions to realize a decarbonized society.

　3-3. We will work to effectively utilize resources and promote resource circulation.

　3-4. We will promote the conservation of water resources and the reduction of waste and chemical emissions.

　3-5. We will strive to mitigate the impact of our business activities on ecosystems and contribute to the conservation of biodiversity

4. Promotion of Fair and Transparent Business Activities

　4-1. We will always conduct open and fair transactions to maintain good and appropriate relationships with our customers and business partners.

　4-2. We will comply with the competition laws of each country and region, including prohibitions against private monopolies, unfair trade restrictions (such as cartels and bid-rigging), and unfair trade practices (such as abuse of superior bargaining position).

　4-3. We will have absolutely no relationship with anti-social forces and will respond to them with a firm stance.

　4-4. We will build sound relationships with others, such as public officials and government personnel, and will neither accept nor engage in gifts, entertainment, or other corrupt practices that are not socially acceptable.

　4-5. We will not provide favors or exchange private benefits, regardless of the pretext.

　4-6. We will participate in political activities and similar endeavors with the understanding that we are participating as individuals.

　4-7. We will recognize the importance of confidential information, including personal information, and information about our company and other companies obtained through business activities, and strictly manage such information by developing an appropriate information security framework and prevent its leakage to external parties.

　4-8. We will handle unpublished material facts of our company and other companies with care and comply with insider trading regulations.

　4-9. We will conduct business-related record-keeping, applications, and reporting based on appropriate evidence (supporting documentation), and perform proper accounting and tax compliance.

　4-10. We will use the company’s assets, whether tangible or intangible, solely for legitimate business purposes and not engage in any misappropriation.

　4-11. To maintain international peace and security, we will comply with trade-related laws and regulations governing imports and exports.

5. Promoting Communications with Society

　5-1. We will strive to disclose information that is useful and reliable for stakeholders, not limited to disclosures required by laws and regulations.

　5-2. We will promote two-way communications with a wide range of stakeholders, including customers, business partners, employees, shareholders, investors, local communities, and government agencies.

　5-3. As a member of the international community, we will respect the cultures and customs of countries and regions while striving to actively contribute to society through our business activities.

6. Responsible Actions

　6-1. We will thoroughly consider and understand the purpose of this Code of Conduct, practice responsible behavior, and establish systems to enable the “prevention,” “early detection,” and “early response” regarding any situation that violates the Code.

　6-2. If we discover any issues that violate this Code of Conduct, we will promptly report them to our supervisor, the appropriate department, or the reporting office. Retaliatory actions against reporters will not be tolerated, and individuals who report in good faith will not be subject to disadvantageous treatment.

　6-3. Should a serious violation of this Code of Conduct occur, management will promptly and accurately explain the situation to society, investigate the facts and causes, and implement measures to prevent recurrence. Management will also clearly define responsibility for the issue and, where necessary, impose strict disciplinary action, including on themselves.

　6-4. We will establish an organizational crisis management system, including preventive measures, to prepare for natural disasters, cyberattacks, infectious diseases, terrorism, accidents, and other threats to our business activities. In the event of any disaster, we will aim for the early restoration of business operations and strive to minimize impacts on customers, business partners, and others.