DISCO Code of Ethics

01. DISCO Ethics
The fundamental theme behind ethics is to live a more ethical life. Exactly the same applies to DISCO as a group of people and a member of society.

In order for DISCO to “live a more ethical life” or “be the best it can be”, DISCO must strictly observe the law in all cases. However, DISCO believes that observing the law is a given. Even within the bounds of the law, moreover, there are things that you should not do or you had better avoid doing. For example, there are legal grey zones where certain behavior is allowed by law but offends against local government ordinances or falls into areas where legal coverage is inadequate. DISCO personnel should not engage in activities in such areas even if they are legal.

In society, there are also various codes that people share. DISCO believes that "DISCO ethics" requires our words and deeds not only to meet legal criteria but also to conform with or even improve on these social codes.

The contents of the Code of Ethics are all totally sensible. To achieve the better society to which DISCO aspires, individual DISCO personnel should understand the spirit of the Code of Ethics and engage in sincere activities in line with their consciences.
02. Obligation to Observe DISCO Ethics
Since individuals belong to society, organizations and similar groups, they are required - and obliged - to take the initiative in making these groups better. Naturally, personnel belonging to the DISCO organization are obliged to make DISCO a better company. That is why you are required to strictly observe the Code of Ethics in your activities.
When you encounter words and deeds that are unethical or offend against the Code of Ethics, or see the possibility that they may occur, you must immediately put a stop to such behavior or call attention to it in order to prevent it. If you do not have enough power to do this alone, or feel it is inappropriate to do so, please report it to the Legal Department or Reports & Allegations . Please remember that observing DISCO ethics means that you should not overlook cases where you encounter unethical words and deeds, as well as not engaging in unethical words and deeds yourself.
03. Let Your Conscience be Your Guide
The Code of Ethics lays down rules concerning the words and deeds of DISCO personnel in the realm of ethics. These rules apply in many different areas, but the Code of Ethics alone cannot cover all aspects of ethical ideals and rules. Nor is it realistic to expect people to constantly confirm the integrity of their daily actions in the light of laws and regulations.

In any situation, we expect you, as DISCO personnel, to make your own judgments through the filter of your own consciences, deciding which of the choices available is the most honest and asking yourselves whether you can truly say with confidence that it is indeed the most honest approach. If you are ever asked to speak or act in a manner that goes against your conscience, you must always adopt a resolute stance and refuse to comply.

Note: In order to "let your conscience be your guide", you may, for example, ask yourself if you can swear to your parents, spouse and children, that your course of action is truly honest.
04. Obligation to Check the Latest Version of the Code of Ethics
The Code of Ethics will be revised as appropriate to comply with new societal demands, changes in the business environment and various other changes. The latest version will be published through the company's database.

DISCO personnel are required to check and gain an adequate understanding of the latest version of the Code of Ethics. This is because the contents of the Code of Ethics are so important that there is no excuse for ignorance of them. You should be fully aware of this, and regularly check for the latest version of the Code of Ethics.
05. Obeying the Law
DISCO personnel must never engage in any behavior that offends against laws or any other kind of regulation. This is the absolute minimum rule for all activities, and DISCO personnel must strictly observe it in everything they do. Obeying the law is an absolute obligation of DISCO, as a member of society, and DISCO personnel. DISCO will take the most rigorous measures if it is recognized that there has been serious misconduct or evasion of the law.
06. Strict Adherence to DISCO VALUES and Internal Regulations
DISCO VALUES focuses on clarifying how DISCO should function as a member of society. But the company also has many other internal regulations. These rules constitute an essential approach to enhancing and preserving the values of DISCO and DISCO personnel within the context of society. DISCO personnel are required to adhere strictly to both DISCO VALUES and internal regulations.
07. Obeying the Anti-Monopoly Law
DISCO must never violate the Anti-Monopoly Law in its business activities. This law prohibits the use of unjust methods to monopolize the market and unjust restrictions on transactions. DISCO personnel must understand the purport of the law and ensure that all competition and transactions are fair.

Laws pertaining to competition also exist in most of the countries where DISCO does business, and must be observed in the same way. Employees who are in charge of the operations in question are asked to confirm and correctly understand the content of these laws. Please contact the Legal Group for details of the Anti-Monopoly Law and laws pertaining to competition in other countries.
08. Obeying the Laws of Foreign Countries and Ethical Criteria
DISCO obeys the laws of countries where it does business. Depending on the country or region in question, however, there may be cases where the legislation is inadequate or differs from legislation in force elsewhere. In such cases, you should not allow yourself to engage in a behavior that is forbidden in your own or other countries simply because it is allowed in one particular country. DISCO also disavows behavior that takes advantage of the different laws and systems in other countries and regions even to the benefit of the company. This is especially important in the matters relating to ethics, human rights and the environment. Please be sure, too, to give maximum respect to the social codes prevailing in different countries and regions. However, you are forbidden to follow such conventions and customs that are clearly in violation of laws and regulations.
09. Intellectual Property Rights
DISCO respects the intellectual property rights held by others and refrains from infringing on them. DISCO must pay royalties to and/or obtain permission of the rights holder, before DISCO employees may use such intellectual property.
10. Protecting DISCO's Intellectual Property Rights
DISCO considers its intellectual property as an important asset, and rigorously protects them. Formal decisions from the divisions in charge are necessary whenever DISCO's property rights are to be transferred to, or used by, third parties.
11. Intellectual Property Rights Associated with Personnel
The rights and benefits of all intellectual property rights created by DISCO personnel in the course of their duties shall devolve to DISCO. Examples of such rights include inventions, know-how, technology, ideas, theories, methodologies, systems and business models. Moreover, within the scope allowed by legislation in the countries involved, they shall devolve to DISCO irrespective of when and where they were created.

DISCO shall compensate personnel for the fruits of such efforts on the basis of the regulations for the handling of inventions and designs. Please consult the division in charge when any doubts arise in connection with this compensation.
12. Protecting DISCO Information, and the Confidentiality Obligation
DISCO shall protect, as assets, the various kinds of information accumulated through corporate activities. DISCO personnel must endeavor to prevent leakage of informational assets outside the company in accordance with the control and management standards stipulated by the company for each category of information. DISCO personnel must not disclose DISCO information acquired in the course of their duties outside the company without going through the prescribed procedures. DISCO personnel are obliged to keep DISCO information confidential and are required to present written pledges to confirm this. You are also required to adhere to this confidentiality obligation even after leaving the company.

Advances in personal computer and networking technology have increased the danger that individuals can manipulate informational assets or we can suffer computer virus attacks from others, so you must make every effort to ensure the safe management of such informational assets.

Note: The extent and the form of nondisclosure agreement on informational assets to be signed by DISCO members shall be in compliance with the laws and regulations of each country.
13. Handling Personal Information
From its standpoint of respecting each person's individuality, DISCO believes it must be extremely careful when handling personal information. DISCO has embraced the principle that personal information belongs only to the person in question.

For example, information provided by individuals is never used for purposes other than those it is intended for. Once the reason for using the information no longer applies, the information must be deleted by the most reliable methods available.

All personal data is strictly managed by the personal data manager, and personnel are never permitted to peruse or use personal data without valid reasons. It is also forbidden to disclose personal data to third parties without the agreement of the individual in question.

"Personal data" refers to all information pertaining to all individuals, including DISCO personnel, customers and suppliers.
14. Double Employment
DISCO personnel are obliged to protect DISCO assets and interests. Consequently, personnel are not allowed in principle to take up employment with companies other than DISCO or start companies as individual business owners (hereinafter referred to as "double employment") because of the possibility that doing so will conflict with DISCO's interests.

However, this does not necessarily apply in cases where conflicts with DISCO's interests are unlikely, such as working as a teacher in a culture class, or serving as a director in a family business. In such cases, you must apply for, and obtain, permission in advance. Another condition is that you must provide a written pledge concerning the rules that you must observe.
15. Transfers to, and Hiring from, Competitors
Limited to cases where the new employer is a competitor, DISCO imposes constraints when DISCO personnel switch employment to other companies. It does this in order to protect the interests of DISCO stakeholders. More specifically, switching employment to competitors of DISCO is prohibited for five years from the date of retiring from DISCO in the case of representative directors, three years in the case of employees of managerial rank and above, and one year in the case of other employees. If you are in doubt as to whether a company to which you are thinking of transferring is a DISCO competitor, please consult the in-house liaison.

Additionally, DISCO will never engage in the act of offering employment to, or poaching personnel from, other companies in order to obtain confidential information from competitors or with other unfair objectives in mind. When hiring, please confirm whether the persons in question possess confidential information pertaining to their previous jobs and, if they do, please take appropriate measures such as destroying or returning this information to ensure that the rights of other companies are not violated.
16. E-mail and the Use of the Internet
E-mail and the Use of the Internet
DISCO's in-house personal computers and electronic mail addresses are the property of DISCO. DISCO personnel are asked to make use of them with a proper understanding of this fact. Please limit use of DISCO equipment for private e-mails and private use of the Internet to rest periods on a sensible basis and with awareness that you are using DISCO property. You will be ordered to halt use in cases where DISCO deems that you are having an adverse impact on those around you or have exceeded the bounds of moderation.

Monitoring Usage
Please be aware that there are cases where a person in charge may monitor or otherwise supervise the contents of e-mails or Internet usage in the presence of a management representative in order to prevent leakage of information and ensure that duties are fulfilled in an appropriate manner.

Submissions to Internet Bulletin Boards
Personnel are free to use their own time and personal computers to access non-company Internet bulletin boards to express their views and exchange information. However, you are forbidden to leak confidential DISCO information, disclose the fact that you are DISCO personnel, or make submissions to bulletin boards using expressions that will reveal this fact. Likewise, you must not maliciously slander DISCO, DISCO personnel or stakeholders. DISCO will take the necessary legal measures against any such behavior. When it is necessary to make submissions, you should discuss matters with your superiors and follow the procedures required to obtain approval.
17. Gifts and Entertainment
As a general rule, DISCO personnel should not accept gifts or entertainment from suppliers. Please follow the prescribed procedures when suppliers invite you to dine with them. If you accept or are asked to accept gifts, please report and discuss the matter with your superior without delay. Superiors shall require that you take appropriate measures, such as courteously returning the gift.

DISCO personnel who offer meals or entertainment to suppliers or accept them from suppliers in accordance with business customs shall ensure that they do so within reasonable limits. DISCO sees the exchange of information as the objective of entertainment. You should always confirm this and provide no entertainment that deviates from this objective.
18. Demands from Suppliers for Rebates and Unreasonable discounts
DISCO does not readily accept demands for rebates or unreasonable discounts. This is because accepting such demands could lead to a reduction in the value of DISCO itself, not just its products.

On receipt of any such demands, DISCO personnel should first discuss them with their superiors. DISCO will then respond in accordance with prescribed procedures.
19. Observing the Buyer's Oath
DISCO transactions must be fair and DISCO personnel are required to respect the Buyer's Oath. It goes without saying that suppliers should not be asked to give rebates.
Buyer's Oath
20. Ensuring Fairness when Selecting Suppliers
DISCO should select suppliers on the basis of fair evaluations. The main criterion for selection is the extent to which potential DISCO suppliers can contribute to the realization of the quality of corporate activity aspired to by DISCO. In other words, it is necessary to ascertain which potential suppliers have the best quality, creditworthiness or corporate stance, or the capacity and readiness to supply the best products and services at the most reasonable cost. In the actual selection process, it is essential to adhere rigorously to procedures where all supplier candidates are evaluated on the basis of the same information and according to the same criteria.
21. Giving Priority to Companies with High Level of Corporate Social Responsibility
DISCO always aspires to more Socially responsible corporate activities, and adheres to this approach when selecting suppliers. If several candidates for the role of DISCO supplier are equal or offer similar conditions, we will give priority to selecting those companies that are engaged in more socially responsible activities. It is not easy to evaluate companies properly according to the level of their social responsibility. However, it should be possible to gain a pretty accurate understanding of a company's social responsibility from careful analyses of the extent to which they are affected by crimes or accidents and their responses thereto, their consideration for the environment and human rights, statements by their managements, working conditions, corporate cultures and their reputations within their sectors and society in general. If you face problems in making a judgment, please consult the in-house liaison.

Note: "Social responsibility" here means "social responsibility in a global perspective, in other words, consideration for the environment, security and human rights, etc."
22. Issuing Orders in Documentary Form
DISCO personnel must not conclude deals concerning product prices, delivery quantities and delivery dates with suppliers on the basis of verbal agreements alone. Any verbal agreements should be put in writing without delay. Also, please take proper care to avoid statements that may be misconstrued as promises because even a verbal promise has the same legal force as a written contract.
23. Prohibition of Negotiating Purchase Conditions Based on Promises of Undetermined Future Business
DISCO does not conduct transactions based on promises of undetermined future business. At the purchasing negotiation stage, DISCO personnel shall not use potential future purchasing quantities as leverage in pricing talks with a view to securing favorable transaction conditions for DISCO. In DISCO purchase negotiations, please avoid anything that upsets the fair relationship between the buyer and the seller.
24. Written Submissions to Media, Speeches and Statements to the Media by Personnel
DISCO personnel need the approval of the director in charge when submitting material concerning DISCO's business to publications or giving speeches about it. This is because there is a strong possibility that these materials or articles will include introductions or references to DISCO know-how and other important information. You must also be very careful when responding to media inquiries or making statements to the media. DISCO personnel shall not damage DISCO's reputation, that is, the assets entrusted by stakeholders, through the messages they issue. Please contact the in-house liaison in advance whenever you receive a request for an interview, etc.

There is a tendency to see any articles, speeches or statements submitted to the media by DISCO personnel as representing DISCO's views, not as personal opinions. You are therefore asked to give careful thought to the content of such messages based on a proper understanding of the quality of corporate activity that DISCO aspires to. Personnel in the position of company representatives or executives should be especially careful and accurate when making statements.
25. Participation in Community Activities and Donations to Communities
DISCO's aspiration is to become a good member of the community. To this end, it participates proactively in essential community activities. DISCO not only participates in these activities as a company, but also encourages DISCO personnel to proactively engage in community activities as good members of society. Donations to the community by DISCO constitute one approach to community activities. DISCO believes that donations should not be made simply in response to requests, but should be planned and made autonomously on the basis of DISCO's perception of its role as a member of the local society and its relationship with the community. The recipients, amounts and nature of donations should be such that they can be explained to stakeholders.
26. Donations and Support for Universities, etc., and Joint Research
DISCO is committed to making a contribution, no matter how limited, to technological progress. As part of this, it makes donations to support research by universities and similar institutions. The same applies to support and donations for joint research. However, this kind of support and donations to universities must be kept within the bounds of common sense.
27. Donations in Connection with Disasters
As a member of society, DISCO wishes to assist people who need support as a result of disasters that cause extensive damage. The extent and methods used for this support should be such that they have the sympathy of DISCO stakeholders. When making donations, the amounts involved shall be determined on each occasion according to the extent of the damage and the relationship with DISCO.

In addition to donations in connection with such sudden, transient disasters, DISCO makes ongoing donations to institutions that are recognized by society for their support activities. DISCO selects these institutions and determines the amounts of donations each year.

DISCO also encourages its personnel to be interested in providing support and making some kind of contribution as members of society in times of disaster. When personnel collect donations in connection with sudden, transient disasters, DISCO shall make a matching donation.
28. Disavowal of Antisocial Forces
DISCO does not and will not have relationships with organized crime, corporate extortionists or other antisocial forces that cause or threaten to cause harm or trouble to society. DISCO personnel shall never make use of antisocial forces, or offer funds, cooperation or assistance to them.
29. DISCO's Stance on Political Activities
DISCO shall not make political contributions of any kind or engage in activities in support of any particular candidate. A company's social influence is both different and greater than that of an individual. Companies do not have the right to vote, but the act of supporting a particular political party or candidate tends to distort the weight of one vote. It is also impossible for DISCO to represent the intentions of DISCO stakeholders because they espouse a variety of political beliefs. With this in mind, DISCO prohibits, as a company, any corporate political contributions or support for particular candidates.
30. Political and Religious Activities by Personnel
DISCO personnel shall not engage in political or religious activities in DISCO facilities or premises irrespective of whether they are held during working hours or not. Likewise, you shall not engage, as an employee, in similar activities targeting suppliers, even in locations other than DISCO facilities or premises. You are also forbidden to use the DISCO company name or assets belonging to DISCO in such activities. Since there is a possibility that such activities will be perceived as DISCO activities when DISCO personnel are involved, they may damage DISCO's reputation for not participating in political and religious activities as a company. On the other hand, DISCO shall not get involved in political and religious activities in which DISCO personnel participate using their own private time and resources.

Notes: In the case of China, "political activities" does not refer to the governmental activities sponsored by the Communist Party.
"Religious activities" here refers to "religious solicitation or religious indoctrination".
31. Participation in Group Activities
DISCO encourages personnel to participate in various groups with a view to gathering a wide range of information concerning business, technology and social trends, as well as creating strong and extensive personal connections. In the same way, it also encourages participation in groups and academic meetings covering technological themes.

When participating for business reasons, however, please make your objectives clear and participate only in events that match these objectives. Also, please obtain your superior's permission in advance. A review of groups in which personnel may participate shall be conducted each year, but all groups with political or religious affiliations are excluded.

Note: In the case of China, "groups with political or religious affiliations" does not include "groups with governmental affiliation" sponsored by the Communist Party.