Coca-Cola Bottlers Japan Holdings Group

Code of Business Conduct & Ethics

Coca-Cola Bottlers Japan Holdings Inc.

January 2018

Code of Business Conduct & Ethics

Contents

1. Acting Righteously with Dignity ............ 1

(1) What Is Expected of Everyone ........... 1

(2) What Is Expected of Managers .......... 2

(3) When Written Approval Is Required . 2

(4) COBCE and Laws, etc. ..................... 2

(5) Raising Concerns ................................ 2

2. Right Conduct .......................................... 4

(1) Business and Financial Records ........ 4

(2) Company Assets ................................. 4

Use of Time, Equipment and Other

Assets

(3) Use of Information ............................. 5

Nonpublic Information

Insider Trading

Privacy, Personal Information

3. Respect of Human Rights ....................... 7

4. Dealing with Stakeholders ..................... 7

(1) Relationship with customers, key

accounts, suppliers, shareholders,

and the community ............................ 7

(2) Dealing with Administrative Bodies . 8

Bribes Are Prohibited

(3) Dealing with Competitors .................. 9

Competitive Intelligence

5. Conflicts of Interest ............................... 10

(1) Determining Conflict of Interest….. 10

(2) Gifts, Meals and Entertainment ...... 10

(3) Outside Employment, Speeches and

Presentations .................................... 12

(4) Relatives and Friends ...................... 12

(5) Outside Service as an Officer or

Director ............................................. 13

(6) Outside Investments ........................ 13

6. Addenda ................................................. 14

(1) Administration of COBCE

7. Collection of Cases................................. 16

Please make use of the conduct examples

and Q&A described at the end of this

document to deepen your understanding

of Code of Business Conduct & Ethics.

The contents of the collection of cases will

be added or revised as needed.

＊The term “the Company” used in the

Code of Business Conduct & Ethics refers

to the entire CCBJH group.

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1. Acting Righteously with Dignity

Coca-Cola Bottlers Japan Holdings Group ("the Company") aims at becoming an excellent company accompanied with dignity. Dignity refers to the state in which the corporate culture that places importance on diversity, human rights, environment, and compliance of laws, regulations and the code of conduct is well-established at a high level in the Company.

Our fundamental principles of management are to be community based and customer-oriented. We seek to enhance our corporate value by complying with all the laws and regulation, acting righteously with dignity based on good social sense, and earning the trust of all our stakeholders.

The Code of Business Conduct & Ethics (“COBCE”) serves as the guide to act righteously with dignity and defines how the employees should conduct themselves as the representatives of the Company. Our responsibilities to the Company, fellow employees, customers (consumers), key accounts (customers), vendors (suppliers), and public administration are also described in COBCE.

We must observe all laws, regulations, and COBCE, act righteously with integrity and honesty at all times under any circumstances, and be accountable for our actions.

(1) What Is Expected of Everyone All the employees in the Company are expected to: Comply with laws and regulations, COBCE, and all the Company rules and workplace

disciplines, including the Employment Regulations. Observe all laws, regulations, and COBCE at all times under any circumstances, use good

judgment and avoid taking any actions that may appear to be improper behavior. Draw a line between public and private affairs, and focus on sensible behavior. Never take

any action that may disgrace the Company or damage its interest, even in private lives. Think through before taking an action and seek guidance. If in doubt, engage in self-

questioning before taking an action. If ever in doubt about what the right conduct may be, ask yourself the following questions:

・ Will it be a violation of any laws and regulations? ・ Is it in line with the corporate philosophy and vision? ・ Is it consistent with COBCE? ・ Is it ethical? ・ Is it supported by customers and people in the society? ・ Is it an action that is considerate of other people's positions? ・ Is it an action that you will not feel ashamed of even before your family? ・ Is it an action that will not be embarrassing to you nor to your Company and its

reputation? ・ Is it an action that will cause no inconvenience even when reported in the newspaper？

If the answer is “No” to any of these questions, don’t do it. If you are still uncertain, ask for guidance. COBCE tries to capture many of the situations

that the employees may encounter, but cannot address all of them. If you are unsure of your judgment or have any questions, you should seek guidance from any of the following:

• Your manager • Legal Compliance Department

(2) What Is Expected of Managers

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① Promote a Culture of Ethics and Compliance Managers should at all times be the model of appropriate behaviors and put the following

into practice. • Ensure that the subordinates you supervise understand their responsibilities

stipulated in COBCE and other Company policies. • Make opportunities to discuss about the contents of COBCE and reinforce the

importance of ethics and compliance with them. • Create an environment where they do not feel hesitant to raise concerns. • Consider conduct in relation to COBCE and other Company policies when evaluating

your subordinates. • Never encourage or direct them to achieve business results at the expense of ethical

conduct or compliance with COBCE or any laws. • Always act to stop your subordinates from violating COBCE or any laws.

② Respond to Questions and Concerns

If approached with a question or concern related to COBCE, listen carefully to what your subordinate wants to convey to you. Ask for clarification or additional information when you feel necessary. Answer the questions as much as you can, but do not feel obligated to give an immediate response. If you cannot respond immediately, consult your supervisor or relevant department to gain guidance. If your subordinate raises a concern that may require investigation under COBCE, contact the Legal Compliance Department.

(3) When Written Approval Is Required

Certain actions referenced in COBCE, such as, the use of Company assets for purposes not related to work, and certain situations where conflict of interest arises require prior written approval (including the use of electromagnetic system) from managers, officers in charge of legal affairs or Legal Compliance Department.

If you are in a situation where you need a written approval, contact your manager who can help you seek the necessary approval. (4) COBCE and Laws, etc.

Employees are expected to comply with COBCE and all applicable laws, rules and regulations. If an act is prohibited by COBCE or law, the provisions of the law take precedence over COBCE.

If you are uncertain which laws apply to you, or if you believe there may be a conflict between applicable laws, consult Legal Compliance Department before taking action. (5) Raising Concerns

If you observe a behavior that concerns you, or that may represent a violation of COBCE, raise the issue promptly. Doing so will allow the Company an opportunity to deal with the issue and correct it, ideally before it becomes a violation of law or a risk to health, security or the Company’s reputation. ① Where to inform or consult

As to where you should inform or consult about issues or concerns, you have several options. You can contact any of the following:

• Your manager • Legal Compliance Department • Internal reporting hot line

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② Anonymity and Confidentiality When you make a report to Legal Compliance Department or through the department

responsible for the whistleblowing system, you may choose to remain anonymous, although you are encouraged to identify yourself to facilitate communication. If you make your identity known, the department responsible for the whistleblowing system and the investigating department will take every reasonable precaution to keep your identity confidential. To help maintain confidentiality, avoid discussing about these issues, or any investigation, with other employees. Because these departments strive to maintain strict confidentiality in all investigations, they may not be able to inform you of the outcome of an investigation. ③ Investigations

The Company takes all reports of possible misconduct seriously. We will investigate the matter confidentially, determine whether COBCE or any law has been violated, and take appropriate corrective action. If you become involved in such investigation, cooperate fully and answer all questions completely and honestly. ④ No Retaliation

The Company values the help of employees who identify potential problems that the Company needs to address. Any retaliation against an employee who raises an issue honestly is a violation of COBCE. The fact that an employee has raised a concern honestly, or participated in an investigation cannot be the basis for any action that adversely affects his/her employment, including dismissal, demotion, loss of benefits, threats, harassment or discrimination.

If you work with someone who has raised a concern or provided information in an investigation, you should continue to treat the person with courtesy and respect. If you believe someone has retaliated against you, report the matter to Legal Compliance Department or department responsible for the whistleblowing system. ⑤ Making False Accusations

The Company will protect any employee who raises a concern honestly, but it is a violation of COBCE to knowingly make a false accusation, lie to investigators, or interfere or refuse to cooperate with such investigation. Honest reporting does not mean that you have to be right when you raise a concern; you just have to believe that the information you are providing is accurate.

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2. Right Conduct

Acting righteously begins within the Company, and includes how we deal with Company records, assets and information.

(1) Business and Financial Records ① Ensure the accuracy of all Company business and financial records. These include

not only financial accounts, but other procedural records such as quality reports, working hours, expense reports, benefits claim forms and resumes.

Ensuring accurate and complete business and financial records is everyone’s responsibility, not just a role for accounting and finance personnel. Accurate recordkeeping and reporting reflects on the Company’s reputation and credibility, and ensures that the Company meets its legal and regulatory obligations. ・ Always record and classify all accounting treatments in the proper accounting period

and in the appropriate account and department. Do not delay or accelerate the recording of revenue or expenses to meet budgetary goals.

・ Estimates and accruals must be supported by appropriate documentation and be based on your best judgment.

・ Ensure that all reports to regulatory authorities are full, fair, accurate, timely and understandable.

・ Never falsify any document. ・ Do not distort the true nature of any accounting treatment. ・ Never assist others to evade taxes. For this reason, payments should be made directly

to the person or firm that actually provided the goods or services. Also, payments should be made in the supplier’s home country, where it does business, or where the goods or services were provided, unless the supplier legitimately designate a payee or sold its accounts receivable to another entity. Exceptions must be approved by managers or in accordance with the Company rules.

② Strive for Accuracy

Employees must always strive to be accurate when preparing any information for the Company, but honest mistakes occasionally happen. Only intentional efforts to misrepresent or improperly record transactions, or otherwise to falsify a Company business record, will be deemed as violation of COBCE.

(2) Company Assets ① Protect the Company’s assets, and use those assets in the manner intended.

Do not use Company assets for your personal benefit or the benefit of anyone other than the Company. Use, protect, and manage the Company assets under the responsibility of each of the employees. ・ Apply the common sense. For example, in case of emergency, you may make a

telephone call from your workplace or send email. Excessive use of private telephone calls and email is a misuse of assets.

Theft of Company assets, whether it is physical theft such as unauthorized removal of

Company product, equipment or information, or theft through embezzlement or intentional misreporting of time or expenses, may result in dismissal and criminal prosecution. The Company treats workplace theft of assets belonging to other employees the same way it treats

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theft of Company assets.

The use of Company assets outside your work, such as using the Company’s business achievements outside the Company or using Company materials or equipment for personal interests, requires prior written approval from your manager or from the relevant department through your manager. You must have this approval renewed annually if you continue to use the asset outside the work. ② Use of Time, Equipment and Other Assets • Do not engage in personal activities during working hours that interfere with your job

responsibilities. Ensure time management and strive to achieve the maximum results within the limited time.

• Using Company computers and equipment for outside businesses, or for illegal or unethical activities such as gambling, pornography or other offensive subject matter is prohibited.

• Taking any opportunity for personal gain that you learn through your position in the Company, or through the use of Company property or information is prohibited.

③ Examples of Company Assets • Company money（sales proceeds, change, etc.）

• Company products and promotional materials • Call • Wireless communication devices • Vehicles • Computer systems and software • Photocopiers • Employees’ working hours and deliverables from their work • Tickets to concerts or sporting events • Proprietary information • Company trademarks

(3) Use of Information The Company’s nonpublic information must not be disclosed to anyone unrelated to the

Company. This includes everything from contracts and pricing information to marketing plans, technical specifications and employee information. ① Nonpublic Information

Do not disclose nonpublic information to anyone outside the Company, including to family and friends, except when disclosure is required for business purposes. Even then, take appropriate steps, such as execution of a confidentiality agreement, to prevent misuse of the information.

Do not disclose nonpublic information to anyone outside the Company, except when disclosure is required for business purposes. Employees are obligated to protect the Company’s nonpublic information at all times, including outside of the workplace and working hours, and even after employment ends.

Retain or discard Company records in accordance with the Company’s record retention

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policies. Company legal counsel occasionally may issue notices regarding retention of records in the case of actual or threatened litigation or government investigation. Employees must abide by the directions contained in these notices, as failure to do so could subject the Company and employees to serious legal risks.

② What Is Nonpublic Information?

It is any information that the Company has not disclosed or made generally available to the public. Examples include information related to: • Information on new products prior to release or new campaigns prior to

implementation • Raw materials of products and production method • Pricing of products and production costs • The Company’s business results, business policies, and strategies • Content of contracts • Personal information of employees, customers, and vendors • Financial data • Major management changes • Mergers and acquisitions • Technical specifications • Inventions • Proposals

③ Insider Trading

Trading in stocks or securities based on material nonpublic information, or providing material nonpublic information to others so that they may trade or using such information for your own trading, is illegal and may result in prosecution.

④ Privacy, Personal Information

The Company respects the privacy of all its employees, business partners and consumers. We must handle personal data responsibly and in compliance with all applicable privacy laws. Employees who handle the personal data of others must: • Act in accordance with applicable law; • Act in accordance with any relevant contractual obligations; • Collect, use and process personal information only for legitimate business purposes; • Limit access to the information to those who have a legitimate business purpose for

seeing the information; and • Take care to prevent unauthorized disclosure.

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3. Respect of Human Rights

Respect for human rights is the foundation of corporate activities, and we must ensure such respect in order to realize the sustainability of the Company and the community in which we do business. In addition, we need to accept diverse value and lifestyles and develop an environment in which each of the employees can use his/her maximum potential and quality. We will strive to create a workplace in which each of the employees is respected as a person and can be motivated to work.

・ We will respect each other’s ways of thinking and positions so that everyone in the workplace can work actively.

・ We will strive to maintain a workplace that is free from discrimination and harassment due to race, gender, color of the skin, nationality, origin, religion, age, disability, sexual orientation, and/or gender identity.

・ We will never commit or tolerate any violence, sexual harassment, power harassment, maternity harassment, and/or other abuse.

・ We will strive to maintain and continue improving the workplace to be a place that is safe, healthy and easy-to-work.

4. Dealing with Stakeholders

The Company’s relationships with stakeholders are critical to our success. We must deal fairly and lawfully with everyone and every organization we encounter.

(1) Relationship with customers, key accounts, suppliers, shareholders, and the community

The Company values its partnerships with customers, key accounts, suppliers, shareholders, and the community. Treat these partners in the same manner we expect to be treated. • Always deal fairly with customers, key accounts, and suppliers, and treat them

honestly and respectfully. • Do not engage in unfair, deceptive or misleading practices. • Always present Company products in an honest and forthright manner. We expect that our suppliers will take no action contrary to the principles of our COBCE.

When we deal with the suppliers, we must make sure that we comply with the “Fundamental Principles of Suppliers”.

① Relationship with customers

Everything we do begins with the purchase of our products by the customers. It is most important that we think about what we need to do to be chosen by customers and act from their point of view. We will offer quality goods and services at all times and ensure to pursue customer satisfaction. • We will offer safe products that customers can use with a sense of security. • We think about what may be the valuable goods and services for customers, listen to

their voices, and understand what they desire. • We will respond to customers' inquires and complaints in a prompt, faithful,

appropriate, and sincere manner. We will also review our actions, ensure to evaluate them, and reflect in the next action in a flexible manner.

• We will not use any representation or indication on products or in advertisement that

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may be misleading to customers. • We will appropriately manage the vending machines and other sales equipment so that

they are kept clean and safe for use at all times. ② Relationship with key accounts

It is essential to have trust and cooperation from our key accounts to perform our business activities. We need to understand the sense of value of each key account and provide them with necessary information to address their issues so that we can aim for mutual prosperity. • We will remain interested in customers and act with passion and sincerity. • We will pay attention to our attire, use cheerful expression and kind words, and offer

friendly attitude. • We will proactively understand customers' issues and solve/improve them together. • We will not commit any action that may hinder free and fair trade and competitions in

the course of performing our business to build relationship with key accounts. ③ Relationship with suppliers

We will develop the relationship of trust with suppliers through fair and equal transactions and strive to coexist with them as a good partner. • We will not have any discussions or agreements as to trade terms that may hinder free

competition. • We will not force our suppliers to accept any unfair terms by using our advantageous

position in the business or restrict suppliers not to do any business with third parties. ④ Relationship with shareholders

We will strive for sound and transparent business operations and raise the corporate value. We will also provide appropriate information in a timely manner and enhance the corporate value through sound and transparent Company activities, thereby fulfilling the expectations and trust of shareholders.

⑤ Relationship with the community

We must strive to sustainably grow and prosper with the community so that we can become a trusted and necessary member of the community. We will fulfill our social responsibility through our business activities and contribute to the realization of further enriched society. • We will aggressively support the community through sports, culture, education,

welfare, environmental preservation activities, etc. • We will try to work on resource saving, energy saving, and recycling in order to

promote environmental preservation. • We will have no relationship whatsoever with any anti-social forces or groups that

threaten the order and safety of civil society and will take the approach in a firm attitude.

• We will strive to improve the corporate image and product image of our group.

(2) Dealing with Administrative Bodies Transactions with administrative bodies are not the same as conducting business with

private parties, and must be handled with care. Be aware that there are certain restrictions applied to the transactions with administrative bodies, and consult with Legal

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Compliance Department if you have any questions regarding these restrictions to be certain that you clearly understand them and can fully comply with them.

As a principle, you must not offer anything to a government official directly or

indirectly.in return for any favorable treatment. If offering anything of value to a government official becomes necessary for any reason, be sure to obtain prior approval from Legal Compliance Department in accordance with CCBJI group regulations for the division of authorities (“Regulations of Administrative Authority”). Also, ensure that any such payments are properly recorded in the appropriate Company account.

① Bribes Are Prohibited

A bribe is giving or offering to give anything of value to a government official to influence a discretionary decision. Examples of bribes include payment to a government official to encourage a decision to award or continue business relations, to influence the outcome of a public administration audit or inspection, or to influence tax or other legislation. Other payments to government officials also may constitute bribery in some countries and regions.

② “Anything of Value”

This phrase literally means anything that might have value to a government official, including cash, gifts, meals, entertainment, business opportunities, Company product, and more. There is no monetary threshold; any amount could be construed as a bribe.

③ Certain Payments May Be Acceptable

Special payments to a government official may be allowable under certain narrow exceptions. Obtain approval from Legal Compliance Department before making any such payment. In some circumstances, Legal Compliance Department may be able to provide blanket approvals for certain well-defined interactions with government officials.

④ Improper Payments by Third Parties

The Company may be held liable for bribes paid by a third-party agent or consultant acting on the Company’s behalf. Take particular care when evaluating a prospective third party who might interact with public administrative organizations on behalf of the Company. You must not engage a third-party agent or consultant if there is reason to believe that the agent or consultant may attempt to bribe a government official.

(3) Dealing with Competitors Employees may sometimes need to collect, share and use information about our

competitors for business reasons. But even in such cases, they must do so only in a legal and ethical manner. We must also respect the nonpublic information of other companies in the same way the Company values and protects its own nonpublic information. .

① Competitive Intelligence

Employees are encouraged to collect, share and use information about our competitors, but to do so only in a legal and ethical manner. Just as the Company values and protects its own nonpublic information, we respect the nonpublic information of other companies.

② Acceptable Intelligence Gathering

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It is acceptable to collect competitive intelligence through publicly available information or ethical inquiries. For example, you may gather and use information from sources such as: ・ Publicly available filings with public administrative organizations ・ Public speeches of Company executives ・ Annual reports ・ News and trade journal articles and publications You also may ask third parties about our competitors, or accept competitive intelligence

offered by a third party, as long as there is no reason to believe that the third party is under a contractual or legal obligation not to reveal such information.

③ Prohibited Activities

The following basic restrictions apply to our ability to gather competitive intelligence: ・ Do not engage in any illegal or illicit activity to obtain competitive information. This

includes theft, trespassing, eavesdropping, wiretapping, computer hacking, invasion of privacy, bribery, misrepresentation, coercion, espionage or threats.

・ Do not accept, disclose or use competitive information that you know or have reason to believe was disclosed to you in breach of a confidentiality agreement between a third party and one of our competitors.

5. Conflicts of Interest

Act in the best interest of the Company while performing your job for the Company. A

conflict of interest arises when your personal activities and relationships interfere, or appear in the eyes of those around you that you are prioritizing your personal interest over the interest of the Company.

This section of COBCE provides rules for some common conflict of interest situations.

COBCE cannot address every potential conflict of interest, so use your conscience and common sense. When you are unsure, consult with your manager or Legal Compliance Department to seek guidance.

Take particular care if you are responsible for selecting or dealing with a supplier on

behalf of the Company. Your personal interests and relationships must not interfere, or appear to interfere, with your ability to make decisions in the best interest of the Company. When selecting suppliers, always follow applicable Company procurement guidelines.

(1) Determining Conflicts of Interest When faced with a situation where conflict of interest may arise, ask yourself: • Could my personal interests interfere with those of the Company? • Might it appear that way to others, regardless of whether they are those who are inside

the Company or outsiders? When unsure, seek guidance.

(2) Gifts, Meals and Entertainment Do not accept gifts, meals or entertainment, or any other favor from customers or

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suppliers if doing so might compromise or appear to compromise your ability to make objective business decisions that meet the best interest of the Company.

We must not commit bribery or exchange any entertainment or gift that deviates from a social common sense. Acceptance of any gifts, meals or entertainment that exceed the following limitations must be approved by your manager.

① Gifts

• Do not accept gifts in exchange for doing, or promising to do, anything for a customer or supplier.

• Do not ask for gifts from a customer or supplier. • Do not accept gifts of cash or cash equivalents, such as gift cards. • Do not accept gifts of more than modest value. • Gifts of symbolic value, such as trophies and statues that are inscribed in recognition

of a business relationship, may be accepted. • Gifts or discounts offered to a large group of employees as part of an agreement

between the Company and a customer or supplier may be accepted and used as intended by the customer or supplier.

② Meals and Entertainment

• Do not accept meals or entertainment in exchange for doing, or promising to do, anything for a customer or supplier.

• Do not ask for meals or entertainment from a customer or supplier. • You may accept occasional meals and entertainment from customers and suppliers if

the event is attended by the customer or supplier, and the costs involved are in line with local custom for business-related meals and entertainment. For example, ordinary business meals and attendance at local sporting events are generally acceptable.

③ Travel and Premium Events

If you are invited by a customer or supplier to an event involving out-of-town travel or overnight stay, or to a premium event, such as the Olympics or World Cup, consult your manager to determine if there is adequate business rationale for your attendance. If there is, the Company should pay for your travel and attendance at the event. Be sure to take necessary procedure to receive that payment according to the Regulations of Administrative Authority.

④ Refusing Gifts, Meals and Entertainment

Make efforts in informing people in advance that you will not accept any entertainment or gift. If you are offered a gift, meal or entertainment that exceeds the limits noted above, politely decline and explain the Company’s rules. If returning a gift would offend the giver, or the circumstances under which it was given preclude its return, you may accept the gift but should notify your manager and report to the Company by taking the necessary procedure predefined in the Regulations of Administrative Authority.

⑤ Gifts, Meals and Entertainment for Customers and Suppliers

Gifts, meals and entertainment for customers and suppliers must support the legitimate business interests of the Company and must be reasonable and appropriate under the circumstances. Always be sensitive to the customers’ and suppliers’ own rules and policies on receiving gifts, meals and entertainment.

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⑥ Tickets and Housing for Personal Use

Tickets to sporting events or other entertainment venues that are offered by a customer or supplier for your personal use, without attendance by the customer or supplier, are considered gifts. They should not be accepted, unless offered to a large group of employees as part of an agreement between the Company and the customer or supplier. The same applies to the personal use of a condominium or vacation home.

(3) Outside Employment, Speeches and Presentations You may not be employed by, or otherwise provide services for or receive payment from,

any customer, supplier or competitor of the Company without prior approval from your manager.

You must have prior approval in accordance with the Regulations of Administrative

Authority before accepting reimbursement for expenses or any other payment for speeches or presentations you have done outside the Company, which include the following cases: • When you are giving the speech or presentation as part of your job with the Company

(except when it is part of the official duties such as Public Relations); • When you are giving the speech or presentation describes your work with the

Company; • When you are formally identified as the employee of the Company in the speech or

presentation

(4) Relatives and Friends Some employees have family members who are employed by or investing in the

customers or suppliers of the Company. These financial interests do not constitute a conflict of interest except in the following cases: • When you have discretionary authority in dealing with any of these companies as part

of your job with the Company; or • When your relative deals with the Company on behalf of the other company. In any of the above situations, you must gain approval from an officer in charge,

manager, or Legal Compliance Department.

You may have friends who are employed by or investing in the customers or suppliers of the Company. If you deal with such a customer or supplier, make sure that your friendship does not affect, or appear to affect, your ability to act in the best interest of the Company. If you are uncertain whether your friendship may create an issue, consult your manager or Legal Compliance Department.

In addition, personal relationships at work must not influence your ability to act in the

best interest of the Company, and must not affect any employment relationship. Employment-related decisions must be based on qualifications, performance, skills and experience.

① Who Is My “Family” Under COBCE?

Your spouse, parent, sibling, grandparent, child, grandchild, mother- or father-in-law, or same or opposite sex partner that you live with are all considered a part of your family. Also included is any family member who lives with you or is financially dependent on you, or on

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whom you are financially dependent. Even when dealing with family members beyond this definition, make sure that your relationship does not interfere, or appear to interfere, with your ability to act in the best interest of the Company.

(5) Outside Service as an Officer or Director In general, you must obtain the necessary approval in accordance with the separately

defined Regulations of Administrative Authority.

(6) Outside Investments Avoid investments that could affect, or appear to affect, your decision making on behalf of

the Company. Specific guidelines apply to ownership of stock of a customer, supplier or competitor of the Company: • If you have discretionary authority in dealing with a company as part of your job, you

may not have any financial interest in that company without prior written approval from Legal Compliance Department.

• If you do not have discretionary authority in dealing with a company as part of your job, you may own up to 1% of the stock of that company.

• You may own more than 1% of the stock of any customer, supplier or competitor only with the prior written approval of Legal Compliance Department.

• You must renew approval from Legal Compliance Department if you continue to own the stock.

① Mutual Funds

These restrictions on outside investments do not apply to mutual funds or similar investments in which the employee does not have direct control over the particular companies included in the fund.

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6. Addenda

(1) Administration of COBCE The Code of Business Conduct & Ethics is designed to ensure consistency in how

employees conduct themselves within the Company, and in their dealings outside of the Company. The procedures for handling potential violations of COBCE have been developed to ensure consistency in the process across the organization.

No set of rules can cover all circumstances. These guidelines may be varied as necessary

to conform to laws or contracts. ① Scope of application

This code shall apply to Coca-Cola Bottlers Japan Holdings Inc., Coca-Cola Bottlers Japan Inc. and its wholly-owned subsidiaries, and Q’SAI Co., Ltd. and its wholly-owned subsidiaries.

② Responsibility

The enforcement of the Code of Business Conduct & Ethics is a responsibility of the Ethics and Compliance Committee and under the supervision of the high level organ. The Ethics & Compliance Committee is comprised of senior leaders representing corporate governance functions as well as operations.

③ Investigation of Potential Code Violations

The Company takes all reports of potential Code violations seriously and is committed to confidentiality and a full investigation of all allegations. The Company’s Audit, Finance, Legal and Compliance personnel may conduct or manage Code investigations. Employees who are being investigated for a potential Code violation will have an opportunity to be heard prior to any final determination.

④ Decisions

The Disciplinary Committee makes all decisions about Code violations and discipline in accordance with Rules of Employment and report to the Ethics & Compliance Committee. Those found to have violated COBCE can seek reconsideration of the violation and disciplinary action decisions.

⑤ Disciplinary Actions

The Company strives to impose discipline that fits the nature and circumstances of each Code violation. The Company uses a system of progressive discipline, issuing letters of reprimand for less significant, first-time offenses. Violations of a more serious nature may result in loss or reduction of merit increase or bonus; or termination of employment.

When an employee is found to have violated COBCE, notation of the final decision, and a copy of any letter of reprimand, will be placed in the employee’s personnel file as part of the employee’s permanent record.

⑥ Reporting of Code Decisions and Investigations

The Ethics & Compliance Committee periodically reports all pending Code investigations and final Code decisions, including disciplinary actions taken, to senior management of the Company and to the high level organ.

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⑦ Signature and Acknowledgement

All employees must sign an acknowledgement form confirming that they have read the Code of Business Conduct & Ethics and agree to abide by its provisions. Failure to read COBCE or sign the acknowledgement form does not excuse an employee from compliance with COBCE.

⑧ Waivers

Waivers of any provisions of this Code for officers of the Company must be approved by the Board of Directors or its designated committee and will be disclosed promptly to the extent required by law.

⑨ Glossary

Employees – Corporate Officers (Directors, Executive Officers, Auditors), permanent employees, contracted employees and employees of companies under contract with the Company, also included part-time employees and non-regular employees in COBCE.

Customers (consumers) – All those who purchase or may purchase our products Customers (consumers) – All those who purchase or may purchase our products

Key accounts (customers) ― Wholesalers, shops, and vending machine locations who carry our products

Suppliers (vendors) – Contracted parties who transport, deliver, or manufacture our products or from whom we purchase raw materials and other materials

⑩ Policies and Guidelines

This Code of Business Conduct & Ethics does not cover all the actions to be taken at workplaces. There are other policies and guidelines that detail what is contained in COBCE or provide explanation regarding what is not included in COBCE. Such policies, etc. are as follows. ・ Human Rights Policy ・ Anti-Bribery Policy ・ Privacy Policy ・ Information Security Policy ・ Regulations for Internal Information Management and Insider Trading Prevention

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7. Collection of cases

1. Business and Financial Records (For more detailed explanation, see p. 4 of the main text

of COBCE.)

Q: A sales manager anticipated that he would not meet his sales target for the month. To make up for the difference, he contracted an external warehouse, to which he send the products, and then recorded the shipments to the external warehouse as sales. Is this a right conduct?

A: What this sales manager did was simply transferring the products in the Company’s inventory to an external warehouse, which is not the same as delivering these products to the customer and therefore should not recorded as sales in the books. This is an act that constitutes a falsified financial record.

Q: To achieve the monthly sales target, I used the credit customer code to create a large volume of fictitious orders and recorded them as sales in the books. Is this a right conduct?

A: Creating fictitious orders for the purpose of achieving the monthly sales target and recording them as sales in the books is a violation of accounting rules. Moreover, using the credit customer’s name without permission to create orders is an act that constitutes a falsification of order placement record.

Q: An employee attempted to obtain Company medical coverage for her adult children by submitting a form falsely claiming that her children were full-time students. Is this a right conduct?

A: The family information that she filed (in her application) is a part of her job-related records, and must be accurate. Falsely reporting that her grown-up children were students and gaining unentitled medical coverage based on this false report is an illegal act that constitutes a falsification of business record. When an employee’s child leaves or graduates from a school and is no longer a student, that employee must promptly report that status change to the Company.

2. Company Assets (For more detailed explanation, see p. 4~5 of the main text of COBCE.)

Q: An employee used a Company computer and equipment during working hours to design and print out invitation card for a celebratory party as a favor for his colleague employee. Is this a right conduct?

A: The Company assets must be used for their intended purposes. Using the Company computer and equipment to design and print out invitation cards for a private celebratory party is a personal act that has no direct connection with Company business. The time spent on designing and printing this process were during the working hours. The employees’ working hours are also Company assets, and using them for purposes unrelated to Company business is an act constitutes a misuse of Company assets.

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Q: A manager repeatedly asked a subordinate to take care of his personal chores during working hours, such as picking up his dry cleaning and shopping for personal gifts. Is this a right conduct?

A: The employees’ working hours are valuable Company assets. The manager should not request the subordinate to take of personal chores. Doing so during working hours is an act that constitutes a misuse of the Company assets.

Q: An employee in the marketing department had access to Company tickets to sporting events to be used for consumer promotions. The employee sent some of the tickets to an acquaintance working at a hotel chain in exchange for free hotel rooms for the employee’s personal use. Is this a right conduct?

A: This employee used such tickets to gain a personal compensation (free lodging in a hotel chain in this case), which is an act constitutes a misuse of Company assets. Admission tickets of events used for consumer promotion are Company assets and must be used for Company business.

Q: I am a manager in the marketing department and have volunteered to teach a course on marketing at a local school. I believe that my students would benefit from the discussions on how our Company develops marketing campaigns. Can I discuss this topic in class?

A: Before discussing this topic, you need to first report it to your manager and gain prior approval in accordance with the Regulations of Administrative Authority. The development of marketing campaigns are part of the achievement of our Company’s business activities and are also the Company’s assets. A large proportion of such information are proprietary, and may be inappropriate to reveal them outside the Company.

Q: Is there any problem with borrowing a part of the collected sales proceeds temporarily if they are returned by the closing date at the end of the week or month, or by the next stocktaking and the balance are adjusted to show the correct figures on the books by then?

A: The collected sales proceeds are Company assets. There is no evidence that the Company has not lent any part of the sales proceeds to this sales rep. Taking out some cash from the collected sales proceeds without permission is an act that constitutes improper acquisition of Company assets and is subject to punishment.

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Q: The novelty goods that have been determined to be treated as disposal items were piled in the dump yard of the sales center. I want to take them home for decoration. And since these novelty goods are popular items, I may consider selling them through net auction and make some petty cash. Since these goods were already disposed items, I don’t find any problem taking them home or selling them. Am I right?

A: You cannot take these novelty goods home without getting the permission to do so from your manager. If the items used for promotion, such as these novelty goods, are not properly used or disposed of, and sold in the market such as through the net auction, the consumers who find that they are sold in the market will lose their trust on Coca-Cola promotions and campaigns. Taking out promotional items that are Company assets and making a personal profit out of them is an act that is subject to punishment.

Q: I used the information device leased from the Company to access an online shopping site and search the household items that I wanted to buy. I found some items that seemed to match my preference so I want to order them through the information device leased from the Company. I don’t find any problem doing that since it will not lead to any damage to the Company. Am I right?

A: Using the information device leased from the Company not for the intended business purpose but for personal shopping purpose is an improper behavior that is not permitted.

Q: I used the information device leased from the Company during my recess while I was out in the field to access an adult site. Since I was on a break, I used this site to relax for a short while. Would it be a problem?

A: Using the information device leased from the Company not for the intended business purpose but for accessing inappropriate websites such as the adult site is an improper behavior that is not permitted, even when such action is taken during the employee’s recess.

3. Use of Information (For more detailed explanation, see pp. 5~6 of the main text of

COBCE.)

Q: An employee was so excited about the upcoming launch of a new product, which he had worked on, that he shared the details of the product with his family and friends. Is this a right conduct?

A: Information about new product launch or promotion that the Company has not yet officially announced to the public is the Company’s non-disclosure information. The employees have an obligation to always protect the Company’s non-disclosure information under any circumstances and are not permitted to disclose them to anyone outside the Company, regardless of whether they are the employees’ family members or friends they trust.

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Q: I received by accident an email where the amount of salary paid to several other employees were written. May I show that to my colleagues?

A: You nor your colleagues have any business reason to know this information. You should delete the email and tell the sender that this email was sent to a wrong destination. You must not disclose this information to others.

Q: I have learned that the Company is considering the acquisition of a small beverage company that is listed. May I acquire the stock of this company in anticipation of the acquisition?

A: Trading based on material nonpublic information is considered as insider trading and is illegal, regardless of whether you are trading the stock of the Company or the stock of another company.

Q: Are we allowed to send the data that contains personal information, such as the pass/fail result of the candidate’s hiring interview by email?

A: If you need to send such information by email, be sure to make it a secure email that is protected by a password. The Company has a legal obligation to securely manage personal data and prevent them from leaking.

Q: Is the annual revenue of the Company that is already disclosed publicly a type of information that we can share with people outside the Company?

A: If that information is already a public knowledge that the Company has disclosed as a listed company, there is no problem sharing it with anyone outside the Company. But if the information on revenue is something that is still not disclosed by the Company, it must, as a matter of course, be treated as the Company’s non-disclosure information and must not be shared with anyone outside the Company.

Q: Are billing prices, trading terms and conditions and manufacturing cost considered a part of information that can be shared with people outside the Company?

A: Leakage of information about the billing prices, trading terms and conditions and manufacturing cost may have adverse effect on the Company’s sales activities or competitiveness against the competitors. They are all a part of highly classified information of the Company and must therefore be treated with utmost care.

Q: I obtained the information about the wholesale price agreed between the Company and Business Partner “A” and shared that information with Business Partner “B” that I am in charge of, which is a rival company of Business Partner “A”. Since then, I found improvement in the business relationship with Business Partner “B” and the volume of orders received from Business Partner “B” increased. Since what I did led to improvement in sales performance, I don’t find it a problem. Am I right?

A: Any business-related material information about our business partners (such as, the trading terms and conditions agreed with them) are non-disclosure information. Unless they need to be disclosed for legitimate business reasons, they must not be disclosed to any third parties.

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Q: I don’t find it a problem to post information about the Company on SNS, since I am limiting the network of SNS users to just family members and friends that I trust.

A: Even when the direct users of the SNS are limited to family members or trustful friends, there is still chance for the information posted on that SNS to be transferred elsewhere by somebody related to these direct users. The distinction between business-related information and personal information posted on the social media is often not clearly defined. But any information related to the Company must be handled with utmost care since all the employees have the obligation to protect Company information under any circumstances, including when they are out of their workplaces, out of working hours, and after they retire from the Company.

Q: I wrote in my personal profile on SNS that I am working for this Company. So the SNS users who can access my profile know that I am an employee of this Company. I don’t find anything wrong about writing freely about the noteworthy incidents I encountered in the Company or the complaints I have about the Company since they are strictly my personal comments I am posting on this network. Am I right?

A: The employees must refrain from making any remarks about the Company that may mislead the readers to hold a negative impression about the Company’s corporate activities or Coca-Cola brand, even when these remarks are made strictly as personal comments. Any posted comments that the readers will be able to recognize as comments written by a Coca-Cola employee must not include any information that may leave a wrong impression to the readers that they are official views of the Company.

4. Human Rights (For more detailed explanation, see p. 7 of the main text of COBCE.)

Q: What kind of actions are considered as power harassment? p

A: Power harassment in the workplace is any action beyond the scope of appropriate work behavior that gives mental and/or physical pain to others working in the same workplace by taking advantage of the higher grade or the sense of superiority over the harassed in the human relationship built in the environment, and as a result, clouds the atmosphere of the working environment The sense of superiority over the harassed is not generated through higher grade, but also through the human relationship built between senior and junior members, between peers, or between those who are more knowledgeable or experienced and those who are not, among various other cases, There is need to watch out for power harassment since it may often not be an act that is obvious, or that brings serious adverse effect on the workplace environment, and rather, builds up gradually unnoticed.

Example: A manager scolded the subordinate by saying “A human being making such a stupid error is valueless. I’m sure your incompetency is something you inherited from your parents”. Such comment is not only a rejection of the subordinate’s personality but also an unreasonable remark that includes information that is nothing to do with the subordinate’s work. The act of this manager is considered a power harassment.

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Q: What kind of actions are considered as compensation-type sexual harassment?

A: Compensation-type sexual harassment in the workplace is any action where the harasser makes sexual comments or motions that are disturbing to the harassed, and which lead to the disadvantage of the harassed when the harassed rejects the sexual-related requests from the harasser, including dismissal, demotion, and wage decrease.

Example: A male employee was in a position to coach a female employee who was recently transferred to the same department as her trainer. After work, the two had dinner together several times. But eventually, the female employee began rejecting the male employee’s offer to go out for dinner. The male employee then began ignoring the female employee in revenge, and stopped coaching her about any job. The act of this male employee is considered a compensation-type sexual harassment.

Q: What kind of actions are considered as environment-type sexual harassment?

A: Environment-type sexual harassment in the workplace is any action where the harasser makes sexual comments or motions that are disturbing to the harassed, and which lead to clouding the atmosphere of the workplace environment to the extent that those working there cannot overlook the disturbing behavior of the harasser.

Example: A female employee spread a rumor about a male employee (A-san) that “A-san has many close female friends in the Company” or “A-san is now going steady with B-san (another female employee in the same workplace)”, not only within the Company but also to others outside the Company (such as, business partners). This rumor made the male employee a subject of ridicule among his colleagues and business partners. As a result, the male employee got depressed and became unable to stay focused on his work. The act of the female employee who spread this rumor is considered an environment-type sexual harassment.

Supplementary information: ① Workplace is a place where the employees regularly work in. It may sometimes also

be the office of the business partner, the site visited in a business trip, inside a vehicle while the employees are doing business, or the venue of after-five party (that can be considered an extension of the employees’ job).

② Both male and female employees can be involved in a sexual harassment that occurs in the workplace as either the harasser or as the harassed. Sexual harassment in the workplace is not limited to sex-related issues between different genders but can also occur between the same genders.

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Q: What kind of actions are considered as maternity harassment?

A: Maternity harassment refers to words and/or deeds about the harassed employee’s pregnancy, childbearing, and use of maternity and/or childcare leave that have been made by the senior or peer members in the workplace and are detrimental to the working environment. Such words and/or deeds that involve the harassed employee’s use of nursing care leave also fall under this category. There is a need to separate maternity harassment from “disadvantageous treatment” which refers to the act by the employer who fires or demotes an employee, transfers the employee to a position that is disadvantageous to the employee or does not renew the contract with the employee, on the grounds that the employee was pregnant, gave birth to a child, used the maternity and/or childcare leave, etc.

Example: A female employee was working as a short-time regular employee during her childcare period. When she was about to leave the office earlier than her colleagues who were working full-time, she heard one say “the workload of our team members got heavier because you leave earlier than them”. She began receiving such bitter remark repeatedly mostly every day, which led to her mental stress. The act of the colleagues making such remark is considered a maternity harassment.

Q: One of my colleagues in the workplace is being repeatedly treated inappropriately from his manager whose words and deeds toward this colleague are so bitter that the atmosphere in the workplace has become very gloomy. I am not sure if the manager’s mean behavior is violating any Company rules, but since it is affecting adversely to the working environment, should I report this matter to the department in charge of receiving such consultations?

A: Please report about the manager’s inappropriate behavior toward this colleague to Legal Compliance Department. This department will study how the situation can be improved and take necessary actions.

Q: I have been suffering from bitter words and deeds I received from another employee in the workplace. But I could not find any concrete evidence to prove his inappropriate behavior. He also threatened me that he will act in revenge if I reported about it, saying “Go ahead and report to anywhere you want. But think of what will happen to you if you do that!” What should I do?

A: The first thing you should do is to consult with Legal Compliance Department. Even if you cannot prove what had occurred to you in the past, the situation you are in right now has to be improved before it gets worse in the future. Any words or deeds that suggest retaliation are considered as a violation of COBCE that prohibits disadvantageous treatment and the regulations set for the whistle-blowing system, and is subject to disciplinary punishment.

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5. Dealing with Stakeholders (For more detailed explanation, see pp. 7~10 of the main text

of COBCE.)

Q: I succeeded in receiving an order from a business partner when I mentioned that “the manufacturer’s list price of this product is ○○ yen.” Is there anything wrong with this?

A: If you told the manufacturer’s list price to the business partner just as an information for their reference, this information alone does not affect the business partner’s decision of the selling price they want to set for that particular product. Therefore, it will not be considered a violation of Anti-Monopoly Act.

Q: I requested the business partner to “please do not set the shop price of this product to any price lower than ○○ yen”. I then succeeded in receiving an order from this business partner after gaining their consent to my request on their pricing. Is there anything wrong with this?

A: Settling a deal based on a prior agreement with the business partner about their shop price (their pricing range) is a violation of Anti-Monopoly Act, since you are putting a condition to the shop price, which is something the business partner has the liberty to decide by themselves based on their business interests, etc.

Q: We settled a deal with the business partner after reaching an agreement about us committing to “pay a rebate of 〇円 yen based on the sales volume, under the condition that the shop price of this product is set to ○○ yen”. Is there anything wrong with this?

A: Restricting the liberty of the business party to decide on their selling price by offering them a favorable condition, such as rebate, is a violation of Anti-Monopoly Act.

Q: A key account asked our sales rep to prepare a lengthy and detailed report containing product information that would take much effort to acquire. The sales rep populated the report with inaccurate data, thinking that submitting the requested report to the key account as quickly as possible was a high priority. Was this a right move?

A: We must always be honest with our stakeholders, including the key accounts, and treat them respectfully. Creating and submitting a report that is populated with false data to the key account is the same as deceiving that account. Any act that is misleading or deceptive is not acceptable. We must exert our utmost efforts to gather the requested information as soon as possible, but if obtaining that information is going to require a lot of labor and time, it is also our duty to explain about it politely to the key account so that we will be able to gain their understanding of our situation.

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Q: When I attended a meeting with a key account together with my team leader, I heard him talk about our Company that I thought were not based on facts. What should I have done?

A: You should have corrected the false statements as much as possible while you were in the meeting. If that was not possible, you should have raised the issue with your team leader, your manager, or other responsible Company personnel after the meeting, and made sure that the key account’s misunderstanding is corrected. Any statements that include intentional lies must never be made.

Q: A public safety and health inspector visited one of our manufacturing plants for inspection. May I give the inspector one case of our products as a sign of good will?

A: No. You should never give anything of value to a government official without prior approval from Legal Compliance Department. Giving our products, or anything else of value, to the inspector under such circumstances could be perceived as a bribe intended to influence the inspector’s review of the plant.

Q: After ending the business meeting with the supplier in the evening, I went out drinking with the supplied under the condition that we split the bill. But the supplier paid everything for what we drank and ate. Since it was difficult to imagine that this supplier’s generous behavior would lead into any big problem, I did not take the trouble to report it as a matter of being entertained. Was this a right move?

A: If the supplier paid everything for the dinner you had with them, it is the same as you have been entertained, even if you were “intending to pay for your share”. In this case, you had to report it as a matter of being entertained after you found that the supplier had treated you the dinner.

Q: The business partner told me that they wanted to give something as a gift to congratulate the promotion of the new Senior Manager. What should I do?

A: When the business partner tells you about their desire to give the Senior Manager a congratulatory gift, normally it is difficult to imagine that it would be something of modest value. Your reaction to reject such offer on the spot without consulting with your manager can be considered an appropriate behavior that is aligned with the Company rules. If you could not determine whether to accept or reject such offer on the spot, respond to the business partner after consulting with your manager or Legal Compliance Department.

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6. Conflicts of Interest (For more detailed explanation, see pp. 10~13 of the main text of

COBCE.)

Q: The employee in charge of a travel agency that was one of our suppliers received a discount service privately from this travel agency that was not offered to any other members of the Company. What should this employee do?

A: Those in charge of selecting suppliers or doing business with them must avoid getting into conflicts of interest by being very careful whether the personal profit gained from the supplier or human relationship built with them may “inhibit our capacity of judgment to consider the interest of the Company as the top priority” or may “appear to be prioritizing personal profit over the interest of the Company”. When those in charge of such roles gain personal benefits from the supplier, such act is a violation of COBCE as the conflict of interest arises. No employees are permitted to receive any personal favors from their business counterparts in exchange of the services they provide as a part of their job.

Q: It is my job to select a supplier for the Company. One of the suppliers being considered is a company owned by my spouse. Do I need to take any precautions?

A: In this situation, your interest in your spouse’s business conflicts, or at least appears to conflict, with your responsibility to select the best supplier for the Company. If you are unsure, you should consult your manager or Legal Compliance Department. The best course of action is either for you not to be involved in the selection process, or for your spouse’s business to be eliminated from consideration.

Q: My brother works for Company X, which is one of our customers, but he has no dealings with the Company. I work as a sales rep, but have had no contact with Company X. I now have been asked to manage the Company X account. What should I do?

A: Tell your manager about the fact that your brother is working for Company X. If your new job as the account manager is going to grant you the discretionary authority to deal with Company X, consult with Legal Compliance Department to seek guidance.

Q: When I participated in a seminar, a ballpoint pen was distributed to all the participants. May I accept this offer?

A: In general, the item offered in such a case is considered acceptable and should be used in the Company. If the offered item appears to be an expensive luxury item (of such as a high-end brand), either refuse the offer or report the matter to your manager and consult with Legal Compliance Department on how you should respond.

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Q: The supplier offered us an assorted confectionary package as a token of gratitude for our good business relationship. Is this something that we should reject?

A: If the assorted package appears to be worth around 2,000 to 3,000 yen, you should accept it this time only, and distribute the confectionary with the members in your department or related stakeholders. There is no need to report it as a matter of being entertained. Be sure to explain to the supplier that it is the Company policy to not accept such kind of offer and request them to refrain from offering us such gift going forward.

Q: The supplier who we are working together for the first time offered us an assorted confectionary package as a token of appreciation for the new business relationship. We accepted this offer but told them to refrain from repeating such generous offer going forward. When we opened the package, we found that there was a gift card worth 10,000 yen inserted in the package. What should we do?

A: You should return the gift card politely to the supplier after contacting them that this is something we cannot accept. But if the supplier insists us to take it this time, accept the offer. Then report it as a matter of being entertained and deposit the gift card to the Company. Never accept such offer as a private recipient.

Q: In the regularly scheduled meeting for safe driving administrators in the community, the members take turn giving a presentation about their activities. This year, it was our turn to give a presentation about the activities we were conducting in our sales center. After I gave the presentation, the meeting organizers offered me a gift card worth 10,000 yen as the gratuity. Since I worked hard on preparing this presentation, I should be the one to accept this gratuity. Is it wrong to think that way?

A: When you gave a presentation as the representative of the sales center that is the member of this meeting, your presentation is considered a part of your Company duties, and is not your personal action. Since the Company policy prohibits the employees from receiving gifts in cash or other forms for actions taken as a part of their job, this gratuity is something that you cannot personally accept, If the meeting organizers insist that you take it to align with other members who have accepted it in the past, accept the offer. Then report it as a matter of being entertained and deposit the gratuity to the Company.

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Q: A business partner requested me to give a presentation about our heat stroke preventive measures. Although I belong to Commercial and this presentation theme is not directly related to the duties I am in charge of, I would like to accept this request and give a presentation about our heat stroke preventive measures, since it will also be a good opportunity to appeal our products. Is there any procedure that I need to take?

A: If you receive a request to give a speech, etc. outside the Company on matters that are not directly related to your duties in the Company, seek prior approval from your manager to do so in accordance with the Regulations of Administrative Authority after showing the contents of the speech or presentation material, etc. to the department that is directly related to the theme and gaining confirmation from this department. If the business partner offers you a gratuity for your presentation, etc., reject the offer. But if it seems impolite to reject it, accept it, report it as a matter of being entertained and deposit the gratuity to the Company.

Q: One of my subordinates is an employee was hired by the Company after working for a competitor until recently. May I ask questions about the competitor to this employee?

A: If you are thinking of asking questions that are related to the duties this employee was in charge of when he was working for the competitor, seek guidance from Legal Compliance Department before doing so. Be sure not to request this employee to share the kind of information that is legally restricted from disclosing, including the confidential information of the competitor.

Q: As I was preparing a proposal to a key account, that key account showed me the contents of what our competitor had proposed to them. ’s proposal so that we can respond. May I accept that information shared from the key account?

A: First, ask the key account whether they have a confidentiality agreement with the competitor that prohibits them from sharing this information. If the account confirms that they are not under any obligation to protect that information, you may accept it. If you, after receiving the document with that information, find that the document is marked “confidential” or “proprietary”, consult with Legal Compliance Department before disclosing or using that information.