Vehicle Energy Japan Code of Conduct

2.1 Proper Transactions

1. We are committed to upholding fair and open competition by adhering to all applicable domestic and international competition laws, and by conducting business with integrity, in full compliance with legal standards and sound corporate ethics.
2. We will unequivocally sever all ties with antisocial forces, reject any improper demands or transactions, and ensure that we do not engage in such activities, regardless of location.
3. We strictly prohibit any trading of securities — whether our own or those of affiliated entities or business partners — based on material non-public information pertaining to ourselves, our affiliates, partners, or customers, which could affect investor judgment.
4. We maintain a strict policy of zero tolerance toward bribery and corruption, and do not engage in any such activities. We refrain from offering or accepting gifts or entertainment that exceed socially accepted norms and that may foster unethical conduct. Furthermore, we strive to build sound relationships with political and administrative bodies, ensuring transparency in all interactions.
5. We comply with all domestic and international import and export laws and regulations, and maintain strict internal controls to support the preservation of international peace and security.
6. In our business activities, we not only comply with applicable laws but also respect the cultures and customs of each country and region, striving to act with integrity and fairness. Even in countries or regions where legal systems or enforcement may be insufficient, we endeavor to uphold the highest international standards expected of a global company.

2.2 Relationships with Suppliers

1. With a global perspective, we pursue optimal sourcing opportunities while fostering fair and equitable partnerships. We are committed to building mutual understanding and strengthening relationships of trust through a long-term perspective.
2. In selecting suppliers, we conduct a comprehensive evaluation not only of the quality, reliability, delivery timelines, and pricing of the materials to be procured, as well as the supplier's financial stability and technological capabilities, but also of their commitment to social responsibility — including the elimination of unjust discrimination, the prohibition of child and forced labor, and active engagement in environmental conservation efforts.
3. We do not accept any personal benefits or gifts from suppliers in connection with procurement transactions.

2.3 Relationship with Customers

1. In delivering products and services, we strive to meet customer needs and specifications, comply with all relevant laws and standards, and, where necessary, establish voluntary internal standards to ensure the highest levels of quality and safety.
2. We strive to communicate with our customers with honesty and integrity, respond promptly and sincerely to any defects or complaints, investigate their root causes, and take thorough measures to prevent recurrence and future issues.

1. We are committed to respecting the human rights of all individuals, and conduct our business activities in accordance with internationally recognized human rights standards and principles.
2. We conduct appropriate human rights due diligence in accordance with the social context of the countries and regions where we operate, as well as the characteristics of our business, products, and services.
3. We strive to identify potential human rights risks in advance and implement mechanisms to prevent their occurrence. Should any violations arise, we are committed to promptly addressing and remedying them through appropriate internal and external procedures.
4. In all aspects of our business activities, including recruitment and employment practices, we respect the human rights of every individual and do not engage in discrimination or actions that undermine personal dignity based on gender, sexual orientation, age, nationality, race, ethnicity, beliefs, religion, social status, family background, illness, disability, or any other characteristic.
5. In employing staff, we comply with the laws and regulations of each country and region, while also adhering to international standards. In particular, we prohibit child labor below the minimum working age and any form of forced or involuntary labor.
6. We respect the laws, regulations, and labor practices of each country and region in which we operate, while aligning with international standards. Through genuine and constructive dialogue between management and employees, we are committed to collaboratively identifying and resolving workplace challenges.

1. We prioritize the safety and health of our employees above all else, and are committed to ensuring workplace safety and promoting the physical and mental well-being of employees, including their families.
2. We are committed to fostering a workplace that supports flexible working practices and respects diverse perspectives, enabling each employee to engage in their work with purpose, motivation, and ambition. Through these efforts, we aim to achieve the sustainable growth of both our organization and our employees.
3. We invest in the necessary education and training to enable employees to fully realize their potential. Employees are expected to continually pursue self-development, while managers are committed to providing fair, appropriate guidance, supervision, and support to foster the growth and capabilities of their team members.

1. We establish a Personal Information Protection Policy and strive for the proper management of personal data. In handling information, we are committed to upholding human rights, ensuring safety, and promoting a strong culture of information ethics.
2. All information related to business activities shall be collected and managed in accordance with applicable domestic and international laws and internal regulations, ensuring appropriate handling and control.
3. We are dedicated to maintaining and enhancing trust-based relationships with our diverse stakeholders by ensuring fair and transparent disclosure of information. Through active engagement and open dialogue, we fulfill our responsibilities and foster meaningful communication.

1. We protect our intellectual property, respect the intellectual property rights of third parties, and utilize these assets effectively to ensure the smooth and efficient conduct of our business.
2. We classify our own and third parties' confidential information according to its level of importance and ensure that it is managed and handled appropriately in accordance with its sensitivity.
3. Recognizing our brand as a vital management asset, we are committed to protecting and enhancing the value of the Vehicle Energy Japan brand through responsible and strategic actions.

All corporate assets shall be used solely for business purposes and legitimate objectives, managed responsibly, and protected to prevent any diminution of their value.

We are committed to systematically addressing threats such as natural disasters — including earthquakes, tsunamis, and floods — as well as cyberattacks and other physical acts of terrorism. We implement appropriate measures to ensure the safety of our employees and the continuity of our business operations.

Employees pledge to act in accordance with this Code of Conduct. In the event they identify any behavior that deviates from the Code, they shall promptly report it to their supervisor or through the internal reporting system.

Executive leadership shall take the initiative in adhering to this Code of Conduct and make every effort to ensure that business operations are conducted in accordance with corporate ethics and applicable laws and regulations. In the event of any violation of this Code, prompt corrective actions and measures to prevent recurrence shall be implemented. Strict disciplinary action shall be taken against the responsible parties, including members of senior management themselves.