Ȩ COMPANY Ethical Management

Ethical Management

All staff and executives of LINESYSTEM are working together to make ethical management solidify.

Ethics Chart
Ethics Standards
1. Attitude of members

1.1 Faithful job performance
1) Members must precisely recognize their authority and responsibility, and carry out their job according to the principles of loyalty and faithfulness.
2) As a general rule, members must not hold concurrent positions, concurrent jobs and/or side jobs, which interrupt job performance. With the consideration of relevance to the Company¡¯s business, however, there is an exception in case of a prior approval by the Company.

1.2 Maintenance of Dignity and Promotion of healthy corporate culture
1) Members must bear in mind that their words and deeds are integral to the Company¡¯s trust and reputation, and they must make the efforts in fulfilling their responsibility and duty.
2) Members must not carry out any actions including sexual harassment, coercion, and an act of giving members other burdens than job performance, which impedes healthy relationship between co-workers or between senior and junior workers, and they must regard themselves as a partner, respect each other, and thereby build a healthy corporate environment..

1.3 Fair job performance
1) Members must draw the line between public and private affairs, transparently carry out their work. Therefore, they must not offer money, treatment and other valuables to those concerned for the purpose of unreasonable and unfair gains and possession.
2) Members must not receive money, treatment or individual convenience from those concerned such as partner companies. If members receive them unavoidable, they must process them in accordance with the ¡®standards of processing gifts and others in case of the delivery and acceptance of them¡¯, and report the chief director about the progress. The following cases, however, are exceptional.
 + Gifts for promotion and events
    - Goods which the Company or business partners mark with their logo and name, and whose prices are universally accepted.
 + Money for congratulations and condolence
    - Money universally accepted in accordance with the purposes of mutual dependence
3) As a general rule, members must report to their boss when they contact business partners regarding their business.

1.4 Resolution of a conflict of interests
1) Members must neither take any actions nor form relations in terms of a conflict of interests with the Company. If any violation occurs, they must report to the chief director.
2) The actions to be taken into consideration in terms of a conflict of interests are presented as follows. The following cases, however, do not include all possibilities, so members are required to make strict judgment and application in an actual circumstance.
 + The following examples are the cases of a conflict of interests, which occur when members are able to exert their work influence, or when their work influence affects members¡¯ judgment and behavior in the process of carrying out their work.
    - A case that members have business relations with the Company, business partners, or competitors through themselves or third parties
    - A case that members take on concurrent positions at companies concerned with no approval of the Company
    - A case that members, through themselves or third parties, have relations with business partners in terms of monetary loan, joint investment, loan guarantee, lease of real or movable property
    - A case that members receive a reward from partner companies through themselves or third parties
 + The following examples are the cases of a conflict of interests, which occur when members wrongfully gain profits by using the business information obtained in the process of carrying out their work.
    - A case that members, through themselves or third parties, purchase assets and securities, which the Company is to buy or lease.
    - A case that members are guaranteed employment and job recommendation of themselves or third parties by giving business partners private advice with the use of the Company¡¯s information
 + Members must report to the chief director in the event that their family members and/or relatives have business relations with the Company and business partners.

1.5 Protection of the Company¡¯s assets and information and Proper use of them
1) Members must neither misuse the Company¡¯s assets, nor either transfer or lease them to third parties in the interests of each individual with no approval by the Company,
2) Members must not misuse the Company¡¯s budget for their own purposes, and must efficiently use it in meeting the Company¡¯s purposes and standards.
3) Members must not excessively use PCs, the internet, e-mails, and phones/faxes for their own personal purposes.
4) Members must actively protect the Company¡¯s intellectual properties, such as patents, business rights, trade rights, copy rights, and other information with asset value.
5) Members must strictly manage the Company¡¯s information assets including business and technical information in accordance with the Company¡¯s information security management standards. The openness of information assets and its scope shall observe relevant laws and bylaws, and the Company¡¯s rules, and interviews with the press outside shall follow suit.

2. Responsibility for customers

2.1 Customer-oriented management
1) The Company constantly works hard to provide products and services for customers by meeting their needs.
2) The Company makes its best effort in understanding the requirements of customers, in respecting their reasonable request and suggestions, and in actively reflecting them into the Company¡¯s management activities.

2.2 Privacy Policy
1) The Company does its best in observing the laws relevant to protection of customer information, in constantly monitoring/improving work process to protect customer information, and in operating the best security system to protect customer information.
2) The Company neither misuses the information obtained from customers for other purposes than its original purpose, nor offers the information to third parties with the exception of the agreement by customers or of the permission of laws.

2.3 Improvement of Customer Value
1) In offering products and services to customers, the Company does the best to maintain the product and service quality to the extent that customers feel satisfaction, and to promote service environments which customers safely and conveniently access.

3. Responsibility for members

3.1 Humanity-oriented management¿µ
1) The Company must respect personality of members and fairly and reasonably treat them according to their capability and performance.
2) The Company must provide members with an environment where they are able to maximize their ability voluntarily and enthusiastically.
3) The Company must support members¡¯ activities to improve their ability, and actively give them opportunities to learn skills necessary for job performance.

3.2 Safety and Welfare of members
1) The Company must overhaul a system necessary for members¡¯ health and safety, and perform relevant education regularly.
2) The Company must make the most effort in order for members to create challenging and innovative ideas and thereby to achieve happiness together with their co-workers.

4. Responsibility for shareholders

4.1 Improvement of Corporate Value
1) The Company must maximize its corporate value through constant innovation and efficient business management, and thereby share its profits with shareholders.

4.2 Protection of Shareholder rights
1) The Company performs transparent management with the centralization of board of directors, and respects fair requests and suggestions by shareholders.
2) The Company must precisely record and maintain accounting information in accordance with accounting principles, relevant laws, and bylaws, which are generally accepted.
3) Regarding all management information, The Company must reflect relevant facts or transaction details, and thereby support the decisions made by its management group.

5. Relationship with Business Partners

5.1 Fair Trade and Win-Win Management
1) The Company gives imperial trade opportunities to business partners, and does not take advantage of its superior position, and pursues mutual interests and development.
2) Regarding matters which possibly violate the laws relevant to fair trade, members must previously discuss staff in charge of fair trade and legal issues before processing them, and must not make a decision according to any arbitrary interpretation.

6. Responsibility for society

6.1 Building a healthy culture
1) The Company contributes to improving the quality of life for all and to promoting happiness in the world by making the world convenient and affluent through constant technological innovation and enhancement of business.
2) The Company observes the general laws and social norms of the region where its business is running, and respects the region¡¯s social tradition and culture.

6.2 Respect of human dignity
1) The Company must not make any irrational discrimination against all people concerned including customers and members in the region where its business is running for the reasons of race, religion, gender and disability.
2) The Company protects fundamental human rights such as protection of minors and of customer privacy in the region where its business is running.

6.3 Eco-friendly management
1) The Company observes the international standards and laws, and bylaws, which are related to environmental protection, and performs eco-friendly management.

6.4 Social Responsibility Activity
1) The Company actively engages in social responsibility activities to make the society happy.

6.5 Political Neutrality
1) The Company respects an individual¡¯s right to vote and political expression, yet does not accept any political activities which are to be taken with the use of the Company¡¯s fund, human resources and facilities.
2) The Company rejects any improper deals with governments, and observes relevant laws of each nation.

7. Application of ethical code

7.1 Targets of Application and Obligation for Compliance
1) This ethical code applies to the Company and its all members, and all members are obliged to observe the ethical code and to swear to follow the code.
2) In case of the violation of this ethical code, proper measures are to be taken in accordance with bylaws.

7.2 Report of violated acts and Protection of reporter
1) A member who finds any violation of this ethical code must report to or notify a leader or the chief director in order to quickly address the violation, and must actively protect the Company and members from the violation.
2) Members are never at a disadvantage with regard to their reasonable report.

7.3 Practical guidelines of Ethical Code and Ethical conduct rules
1) Regarding the enforcement of this ethical code, executives being in charge of ethical management are entitled to establish and enforce ¡®practical guidelines of ethical code¡¯ if necessary.
2) Executives being in charge of ethical management are entitled to recommend the establishment and enforcement of ¡®ethical conduct rules¡¯ with the consideration of job features by discussing the general director of a relevant division.

Supplementary Provisions

1. Date of Enforcement
This ethical code shall become into effect on 1 Jan. 2011