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Code of Conduct

For the appropriate and healthy development of Macromill, it is essential for all of its officers and employees (including full-time employees, contract employees, part-time employees, commissioned employees, dispatched employees, and seconded employees; the same applies hereinafter) to fully understand their social responsibilities required in all corporate activities and act in accordance with social ethics. Based on this belief, the Macromill Code of Conduct sets forth the principles that the Macromill's officers and employees must adhere to in their daily work to ensure alignment with the Macromill's management philosophy.

  1. Compliance with laws and regulations

    1. Compliance with related laws and regulations

      Macromill complies with all applicable laws, regulations, ordinances, and other rules in all its business activities.

    2. Healthy employment and labor

      Macromill adheres to all applicable employment and labor laws and regulations, ensuring a safe and healthy working environment.

    3. Fair and free competition

      Macromill will not engage in bid rigging, cartels, or any other actions that obstruct fair and free competition in its business activities. Macromill will conduct its operations in compliance with applicable laws and regulations, including the Anti-Monopoly Act.

    4. Prevention of conflicts of interest

      Macromill does not accept any actions that serve personal or third-party interests at the expense of the Macromill's legitimate interests.

    5. Prohibition of Insider Trading

      Macromill will refrain from any insider trading or activities that could be perceived as such in compliance with all applicable laws and regulations, including the Financial Instruments and Exchange Act and internal regulations.

  2. Relationship with society

    1. Environmental protection

      Macromill seeks to conduct environmentally friendly business activities that enable it to coexist with the verdant natural environment and protect the global environment and natural resources.

    2. Political activities and political funding

      Macromill adheres to all relevant laws and regulations concerning elections, donations, political activities, political funding, etc.

    3. Attitude toward antisocial forces

      Macromill is committed to firmly opposing antisocial forces and will not give in to their demands.

  3. Respect for human rights

    1. Prohibition of discrimination and harassment

      Macromill respects the fundamental human rights of individuals and eliminates unfair discrimination based on nationality, gender, creed, or social status, etc. Macromill strives to ensure a workplace environment free from sexual harassment, workplace bullying, and other forms of harassment.

    2. Prohibition of forced and child labor

      Macromill does not hire individuals below the minimum employment age and does not engage in unfair labor practices, such as forcing employees to perform hard labor against their will.

  4. Honest business activities

    1. Safety and quality of products and services

      Macromill fully understands the significance of safety and quality in the products and services it offers to its clients and strives to ensure them.

    2. Creation and management of accurate information

      Macromill creates and manages accurate records of business information and actively collaborates in internal and external audits and inspections.

    3. Proper accounting and tax filing

      Macromill properly records entries in accounting books and processes vouchers and other documents, and does not make any false or fictitious entries in its books. Macromill conducts rigorous accounting and files precise tax returns.

    4. Respect for and protection of intellectual property rights

      Macromill respects intellectual property rights, including copyrights, trademarks, and patents, in all of its business activities related to products, advertisements, and services. Macromill is dedicated to protecting its own rights while also respecting the rights of other companies.

    5. Protection of personal information

      Macromill understands the significance of personal information, including that of its clients and survey respondents. It is committed to managing personal information properly and securely in compliance with applicable laws and regulations and Macromill's privacy policy.

    6. Management of confidential information

      Macromill is committed to properly and securely managing confidential information obtained from clients, partner companies, and others in the course of its business activities, as well as its own confidential information. Macromill will use this confidential information solely for Macromill's business operations. Macromill's officers and employees will comply with confidentiality obligations regarding confidential information, both during their employment and after leaving Macromill.

    7. Gifts and entertainment restrictions

      Macromill will not engage in bribery or any actions that deviate from standard business practices regarding the giving and receiving of entertainment and gifts.

    8. Establishment and maintenance of an Internal Whistleblowing System

      Macromill strives to establish and maintain its internal whistleblowing system. The goal of the system is to ensure that any actions taken by officers or employees during business activities that clearly violate or there is a risk that they violate laws, regulations, company policies, this Code of Conduct, internal regulations, or other rules are reported internally and addressed appropriately. Macromill guarantees the anonymity of whistleblowers and prohibits any retaliation against them.

    9. Appropriate advertising and promotions

      Macromill will not make any factually inaccurate representations or representations that could mislead clients about the quality and specifications, etc. of its products and services in advertising and promotional activities.

    10. Management of company property

      Macromill utilizes its tangible and intangible assets exclusively for legitimate business purposes and strives to prevent their misuse for malicious purposes that could lead to losses, damage, or theft.

End

(Supplementary provisions)
Established
June 30, 2016
Enforcement
June 30, 2016

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