Code of Corporate Ethics and Conduct

Range of Application

On November 16, 2017, in response to the globalization of the OS Group, the Board of Directors of OUTSOURCING Inc. decided to amend the OS Group’s code of corporate ethics and conduct. This OUTSOURCING Group Code of Corporate Ethics and Conduct (hereinafter “this Code”) defines the basic internal code of conduct to be observed by all directors, officers and employees (regardless of the type of employment; hereinafter “employees”) of OUTSOURCING Inc., its group companies and other controlled affiliates (all together, hereinafter “the Group”). Amendment to this Code requires the approval of OUTSOURCING Inc.’s Board of Directors.

Each company of the Group must adopt this Code as its code of conduct and take the necessary actions in order for all of its directors, officers and employees to fully understand and comply with this Code. Each company is to take measures, such as defining the procedure for imposing disciplinary punishment on those who fail to comply, such that this Code is complied. Although each company is allowed to establish its own code of conduct in adherence with the laws and regulations or custom of its country or region, with the specific nature of its business, etc., such code of conduct must include and be consistent with this Code. Such code of conduct specific to a company will also be considered as a part of this Code.

Objectives of the OUTSOURCING Group Code of Corporate Ethics and Conduct

This OUTSOURCING Group Code of Corporate Ethics and Conduct declares that the Group and its directors, officers and employees act honestly and in accordance with high ethical standards. All directors, officers and employees are required to fully understand and comply with this Code.

1. Ethical Conduct

We must not commit illegal or antisocial behavior that poses a threat to social order and safety, whether during work or outside of work. We must not engage in any behavior that encourages the activities of antisocial forces and organizations. We will strive to enhance corporate value by always being aware of our status as directors, officers or employees and acting with dignity and decency.

2. Compliance with Laws and Regulations

We will comply with all applicable laws and regulations of the countries and regions in which we operate and with our internal regulations including this Code, and will strive to follow sound business practice and corporate ethics in all corporate activities.

3. Healthy Business Activities

We will promote sound business practice in order to prove ourselves worthy of the trust of our stakeholders (all interested parties including shareholders, customers, employees, suppliers, business partners, local communities and other organizations). We will not act against ethical and fair business through, for instance, insider trading, conflicts of interest and corrupt practices. Regarding these unethical activities, we will establish regulatory provisions in detail for each.

4. Appreciation of Diversity

The OUTSOURCING Group conducts business in many countries and regions. We must carefully consider the cultural and regional differences of each and perform our duties accordingly.

5. Respect for Fundamental Human Rights and Equality of Employment Opportunity

We will respect fundamental human rights, will ensure equality in employment, and will appreciate the improvement of working conditions. We will not discriminate based on one’s birth, nationality, race, ethnicity, belief, religion, sex, age, disability or other personal attributes.

6. Prohibition of Forced Labor and Child Labor

We will not use forced or involuntary labor. Neither will we use child labor. The definition of “a child” depends on the laws and regulations of the country or region in which each of the Group’s company is registered.

7. Work Environment and Prohibition of Harassment

We will strive to create a healthy and positive work environment with mutual trust that is free from discrimination or harassment. Violence, power harassment, sexual harassment and any other speech or action considered as harassment are prohibited.

8. Safety and Health Management

We will work to prevent industrial accidents and maintain good health through a comprehensive safety and health management.

9. Protection of Confidential Information

We will strictly manage our companies’ confidential information (such as information that is not disclosed to the public, information that gives us an advantage over our competitors and information that would cause unfavorable consequences if inappropriately disclosed), and we will not disclose or leak such information based on individual decisions, not only while in office but also after retirement. Information also must not be used illegally or unfairly. Furthermore, confidential information of customers, suppliers, business partners, competing companies, etc., must not be accessed and obtained.

10. Protection of Personal Information

We recognize the importance of protecting personal information. In accordance with the personal information protection policy, internal regulations, etc., we will appropriately manage personal information, for instance, upon its acquisition, storage, use, disclosure and disposal. In addition, by taking the necessary and appropriate security measures, we will strive to prevent the leakage, loss and damage of personal information. Furthermore, we will take appropriate measures to protect personal information based on the laws and regulations of each country or region, such as the General Data Protection Regulation (GDPR) in European Union (EU) and the Personal Data Protection Act (PDPA) in Singapore.

11. Internal Reporting

We encourage our members to immediately report cases in which our companies’ business activities, etc., are or will likely be in violation of this Code, the laws and regulations of a company’s country or region or other codes. Additionally, we will keep improving the internal reporting system for verifying and processing the contents of such reports. We will keep all reports confidential and will strive to maintain the anonymity of the reporting person as much as possible, as well as prohibiting any retaliation against the reporting person.

12. Information Disclosure and IR Activities

OUTSOURCING Inc. is a public company, and its shares are listed on the Japanese stock exchange market. Through this market, investors around the world can buy and sell shares. Therefore, in order for investors to be able to make investment decisions based on accurate information, OUTSOURCING Inc. has the obligation to publicly disclose various kinds of information, including the activities of each of the Group’s companies, in accordance with the Japanese securities-related laws and regulations. By disclosing information in a timely, lawful, necessary and sufficient manner, we will actively communicate with our shareholders and other stakeholders in an aim to become a company with highly transparent management trusted by the Japanese as well as the international society.

13. Contribution to the Local Community

As a member of the local community, we will contribute to the healthy development and harmony of the local region through daily activities, including participating in social contribution activities.

14. Environmental Conservation

We recognize that creating a sustainable society is important for the continuity of business activities and will proactively engage in protecting the natural environment. We will promote practical solutions such as paperless payroll statement.

15. Recording and Reporting of Information

As our policy, we will make records and reports such as account books, audit reports, etc., accurately and appropriately. We promise to comply with this policy.

16. Protection of Intellectual Property and Management of Asset

We will use the Group's intellectual property and business assets (tangible assets as well as intangible assets such as trademarks, know-how and information systems) only for legitimate business purposes. Moreover, we will not illegitimately use the intellectual property and business assets of third parties.

Supplementary Provisions

This Code is active as of January 17, 2008 (original version).

Revised: November 16, 2017
Revised: May 16, 2018
Amended: December 17,2018