Compliance|Sustainability|ULVAC, Inc.

Compliance

We emphasize not only compliance with laws and regulations but also compliance with internal codes and ethical codes. As well as conducting awareness-raising activities so that each person in the ULVAC Group acts with a spirit of compliance, we have established and are operating a range of institutions and regulations to ensure thorough compliance.

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ULVAC Group Corporate Code of Ethics
Introduction 14 Proper Handling of Information Proper Handling of Information
1 Research and Development, Products, and Services Safe and High-Quality Products and Services 15 Ensuring Information Security
2 Creative Product Development and Technological Innovation 16 Timely and Appropriate Disclosure of Information
3 Ethical Research and Development 17 Protection of Intellectual Property
4 Ethical Conduct Compliance with Laws and Regulations and Respect for International Norms of Behavior 18 Respect for Privacy and Protection of Personal Information
5 Appropriate Accounting Practices and Tax Payment 19 Appropriate Communication of Information
6 Appropriate Import and Export Control 20 Enhancement of Human Capital and Respect for Human Rights Respect for Human Rights
7 Fair Trade and Competition 21 Non-Discrimination and Harassment-Free Workplace
8 Prevention of Bribery and Corruption 22 Respect for Workers' Rights
9 Prohibition of Conflicts of Interest 23 Safe and Healthy Workplace
10 Prohibition of Insider Trading 24 Promotion of Diversity, Equity, and Inclusion (DEI)
11 Prohibition of Money Laundering 25 Living in Harmony with Society Environmental Responsibility
12 No Relationship with Anti-Social Forces 26 Contribution to Society
13 Responsible Procurement Practices Whistleblowing System

Compliance Education

We conduct company-wide education on compliance, prevention of insider trading, prevention of harassment, prevention of misconduct in research activities, etc., for all employees of ULVAC, Inc. every year and the attendance rate is 100%. The education is designed to raise awareness not only in terms of knowledge but also to enable our employees to act appropriately.

Whistleblowing System

In addition to an internal reporting system whose independence is guaranteed, we have established an external reporting system to comply with laws and regulations, such as the United Nations Guiding Principles on Business and Human Rights and Japan's Whistleblower Protection Act. We have established a system that gives due consideration to maintaining confidentiality during the investigation process. We have established a reporting system that allows whistleblowers to report with confidence, either anonymously or under their real names, so that we can quickly detect misconduct and take appropriate corrective action. We protect the personal information and privacy of whistleblowers and do not tolerate any retaliation or harassment against them. When an internal report is received, the first step is for ULVAC's Compliance Committee to investigate the facts. This investigation is conducted with particular attention to fairness, carefully and thoroughly. As necessary, we engage external experts to conduct meticulous and extensive interviews and their analysis. Furthermore, the Compliance Committee is chaired by the President of the Company, and its members themselves are bound by strict confidentiality obligations in its operation.

Handling of Violations

In the event that, based on the results of an investigation by the Compliance Committee, it is deemed that a violation of laws or regulations has been committed, then the opinion of an external expert, such as a lawyer, may be sought as necessary, steps will be taken to ensure that the violation ceases with immediate effect and improvement measures will be implemented, and those involved in the violation will be dealt with after deliberation by the appropriate bodies. In addition, the root causes of the violation are also investigated in order to formulate effective measures for preventing recurrence.

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