Based on the Basic Guidelines on Corporate Activities, Nippon Carbide Industries Group has established the following Behavior Standard all directors and employees shall comply with.
In modern society, it is common sence that we shall conduct corporate activities legally as a corporate citizen.
Fathermore, social demands for corporate ethics are also expected to become more stringent in the future.
It is possible that individual illegal act shake the foundation of a company's existence. The logic of "for the sake of the company" does not apply.
We shall be aware and responsible for our individual behavior.
Also, those in control should be aware that they are responsible for ensuring that their subordinates comply with these standards.


1.Compliance with laws and regulations

Needless to say, compliance with laws and regulations should be a top priority.

Please make sure that you do not act against the law.
Pay particular attention to the strict observance of the following laws and regulations, which are closely related to corporate activities.

(1)Prohibition of Acts Obstructing Fair Competition
Ensuring fair competition is a rule that must be complied with in corporate activities.
It is prohibited to engage in or participate in activities that violate the rules of the economy market such as the following cases. It is important to ensure fair competition not only for those directly involved in sales activities, but also for all corporate activities.
・Unreasonable restraint of trade (Agreed and executed by the same business operator to take concerted action on price, quantity. e.g.Cartel, bid rigging, etc.)
・Unfair trade practices (To impose conditions on the counterparty not to do business with a competitor, to instruct the distributor on the selling price, or to unilaterally decide on the terms of business with a weak counterparty or subcontractor by taking advantage of its strength.)
・Disparagement of other companies (To disparage another company or to make statements about potentially false or misleading views )

(2)Prohibition of Insider Trading
Insider trading is an act that impairs the soundness and fairness of the securities market and is regulated by laws and regulations in each country. Insider trading involves buying or selling stocks based on important information within the company that influences the stock price (Include material information about subsidiaries.), encouraging others to trade, or providing internal information.
Undisclosed internal information, such as financial affairs, research and development of new products and technologies, corporate acquisitions, and the launch of new businesses, has a significant impact on stock prices. Therefore, when you are in charge of such operations (when you learn about them through your duties), you should ensure thorough information management.

(3)Prevention of Leakage of Trade Secrets
Unauthorized disclosure of trade secrets (Financial information, know-how, product information, manufacturing process information, customer lists, personnel information, etc.) and unauthorized acquisition, disclosure and use of trade secrets of third parties are prohibited. Our group also requires employees to maintain confidentiality not only while in office but also after retirement.

(4)Protection of Personal Information
Personal information is acquired and managed appropriately and used within the scope specified by the purpose of use. When we outsource personal information or provide it to a third party, we will comply with the laws and regulations of each country and handle it properly.

(5)Compliance with Laws Pertaining to Exports
Developed countries, including Japan, the United States, and European countries, have established an international export management regime to coordinate globally to manage exports of goods that may be used or diverted for weapons. The person in charge of exports shall fully understand the laws and regulations pertaining to exports and imports, such as the Foreign Exchange and Foreign Trade Law of Japan, the Export Control Reform Act of the United States, the Common Export Regulations of the EU, and the China Export Control Law.

2.Prohibition of Conflicts of Interest between the Company and Directors / Employees

(1)We must act in good faith and fairly with respect to the Company, and we must seek the interests of ourselves or a third party and avoid acts that harm the Company's interests.

(2)If you or an individual close family member or a corporation operated by such person are business partners in your company, please obtain the approval of each company's board of directors in advance for officers and the approval of the person in charge of compliance for employees.

3.Prohibition of Fraudulent Transactions

(1)Although there is no actual entity such as fictitious purchase, sales, inventory, etc., it is strictly prohibited to carry out disguised transactions or prepare documents as if they exist.

(2)Comply with financial and accounting rules, prepare accurate , and reporting and execute budgets in good faith according to the established rules.

4.Fair use of Company Assets

We shall not use any tangible or intangible company assets including Materials, inventories, equipment, consumables, information, and computer networks to which the company is entitled for any purpose other than that which relates to the company’s business.
 In particular, with regard to information, you must not access, copy, steal, frasify, leak information that is not necessary to know in the course of your business, and it is must be prevented from happening to information you manage.

5. Appropriate Political Activity

(1)You must execise caution in case donations to political parties and politicians are restricted by the country

(2)It is not allowed to support a specific political party or political organization, request to join or support the party or organization and force voters to vote against the specific candidates.

6.Promotion of Environmental Preservation / Safety and Disaster Prevention

(1)In addition to complying with environmental laws and regulations, we shall always pay attention to environmental prevention and cooperate with company's measures to reduce environmental impact at every stage such as technology development, product design, procurement, production, sales, transportation, use and disposal and collection.

(2)We shall comply with the safety related laws and regulations and cooperate with the company's measures to prevent the occurrence of disasters such as explosions, fires, and leaks.

7.Improvement of Employment and Work Environment

(1)At the workplace, safety must be given top priority and a good working environment must be established. At the same time, we must comply with health and safety laws and internal regulations, and strive to prevent the occurrence of injuries and illnesses.

(2)We shall respect one another’s human rights, personalities, individuality, experiences, and other aspects of diversity, and we shall provide equal opportunity to all.

(3)Respect for each other's personalities, and sexual harassment against the will of the other person or harassment based on superiority in the course of duties are prohibited.

8.Moderate Handling of Entertainment and Gifts

(1)Bribes against politicians and public officials are banned in many countries. Entertainment and gifts shall also be conducted in an extremely restrictive manner so as not to cause suspicion.

(2)With regards to entertainment and gifts to business partners, it is permitted as long as it is in consideration of business practices. It is not allowed to provide expensive and inapproproate entertaiment, gifts of maney.

(3)We shall not receive or request any money or other personal benefits directly or indirectly from our group's customers, suppliers, partners, financial institutions or other business partners that may affect your business relationships. Mid-year gifts, year-end gifts, congratulations and condolences, etc., should be limited to business rituals. If you receive something that you consider to be expensive, or if you are unsure of your decision, please make sure to report it to your supervisor.

9.Separation from Anti-Social Forces

We shall not provide any funds or benefits to anti-social forces and use anti-social forces in our business activities, to solve issues, or for any other purpose. In addition, we shall not give in to threats and extortion from anti-social forces, and if we receive threats or unreasonable claims, we shall promptly contact the compliance officer, notify the authorities through the compliance officer, and follow their instructions.

*Anti-social forces are a concept unique to Japan and refer to groups such as organized crime groups that pursue profits by using violence, force, and deceitful methods to make unreasonable demands, and broadly refer to criminal organizations and their collaborators.