Basic Policy

We clarify our social responsibilities in our business activities by our corporate
philosophy of “We will make a contribution to the happiness of our employees and
prosperity of the society through the development of the company”. In order for us to be
accepted, trusted, and loved by the society and to continue a sustainable development as
a company where its employees can work with confidence and pride, it is important that
all companies of the Nadex Group and each of its executives and employees act with
high moral values.

We specify the basic rules to be observed in “The Nadex Group Code of Conduct” as a
corporate code of conduct to be applied to all companies of the Nadex Group and in “The
Nadex Group Employees Code of Conduct” as a code of conduct for its executives and
employees. The Nadex Group will aim to gain greater trust from the society and to
become a company which contributes to realize a sustainable society by observing and
actively practicing these codes of conduct.

Moreover, these codes of conduct are established as a part of CSR (Corporate Social
Responsibility).

1. Purpose of Our Corporate Business Activities
As a R&D oriented company, the NADEX Group will aim at developing and providing
our customers with socially valuable products and services with great consideration to
its safety. By doing so, we will gain customer satisfaction plus trust and contribute to
the development of the society and make efforts to elevate our corporate value.

2. Fair and Appropriate Corporate Business Activities
In our corporate business activities, the Nadex Group will comply with laws and
regulations as well as with internal company rules. We will engage in fair and free
competitions and in appropriate business transactions.

3. Information Management and Transparency
The NADEX Group will manage information in an appropriate manner. We will also
aim at transparent corporate management with active communications with the society
as well as our stakeholders and disclose accurate corporate information in a timely and
appropriate manner.

4. Respect for Human Rights and Corporate Employees
In our corporate business activities, the Nadex Group will regard our corporate
employees as important human assets of the company and respect their individual
diversities and personalities. Moreover, we will comply with applicable international
and national laws and regulations and will take no part in child labor or forced labor.

5. Safe and Pleasant Working Environment
The NADEX Group will eliminate discriminatory treatment and harassment and
realize an open and pleasant working environment.

6. Consideration to the Natural Environment
In the recognition that environmental conservation is a common issue for all humanity
as well as an essential facet of corporate existence and activities, the NADEX Group
will make voluntary and aggressive efforts to conserve environment.

7. Attitude to Antisocial Forces
The Nadex Group will deal with antisocial forces and groups which threaten orders and
security of civil society in a resolute manner.

The top management of the Nadex Group will regard the realization of this code of
conduct as its responsibility and will take the lead in implementing it thoroughly in the
Group. Moreover, the top management will always listen to opinions within and outside
the company and consolidate effective systems of the Nadex Group and also aim at
enforcing corporate morals. When events which violate this code of conduct occur, the
top management will show its attitude within and outside the company to resolve the
problems and strive to investigate the cause and prevent its reoccurrence. Furthermore,
it will make a timely disclosure of appropriate information and fulfill its responsibility
to explain about the issue. The top management will then punish those involved
including itself severely after making authorities and responsibilities clear.

This code of conduct is applicable to all executives and employees of the Nadex Group
including its loaned employees, fixed-term employees, contracted employees, part-time
employees, and dispatched workers.

1. We respect human rights and realize an open working environment.
(1) We do not take any action that constitutes discrimination based on race, creed, sex,
social status, religion, nationality, age, physical and mental disability, sexual
orientation and the like.
(2) We will respect individual personalities and characters and realize open working
environment in which our employees can exchange their opinions freely so that all
executives and employees with abundant individuality and with the spirit of
6C(Creation Challenge Communication Customer-first Confidence Contribution)
can fulfill their potential.
(3) In the workplace, we will not corrupt its moral, environment, or order by acts which
violate public order and morals such as sexual and power harassment.

2. We will comply with laws, regulations, internal company rules, and the like and will
not take actions that violate these laws and rules.
(1) With consciousness of being a member of society, we will comply with laws and
regulations and will take actions which follow accepted social norms.
(2) When we have doubts about interpretation of laws, regulations, and the like, we will
confirm with administrative and external experts and departments in charge within
the company. We will take actions only after we gain an accurate understanding of
the doubts in question.
(3) We will not engage in illegal acts including those which can potentially violate laws.
1. We will avoid agreements with competitors relating to pricing and allocation of
the volume of sales, territories, and customers.
2. We will take no part in bid riggings such as agreements related to bidders and
bid prices.
3. We will not engage in unfair business transactions such as boycott, re-sale price
maintenance, tying, and the like
4. We will not damage the interests of sub-contractors of the company through the
unjustified demand to reduce purchase prices, rejection to receive goods, return
of goods or delay of payment of purchase prices.

3. We will draw a strict line between public and private affairs and will not engage in
any action in which our personal interest conflicts with that of the company.
(1) We will not take any action which damages interest of the company for the purposes
of gaining personal or the third party s interests.
(2) Corporate assets and information systems are provided for business purposes and
we will not abuse them.
(3) We will not be engaged in any other occupation without the prior consent of the
company.
(However, regarding overseas subsidiary companies, the applicable provisions of the
said countries shall prevail.)
(4) We will not purchase stocks from existing or potential business partners of close
companies without the prior consent of the company.

4. We will keep the giving and receiving of gifts as well as entertainment within
reasonable bounds so as to comply with all applicable laws and regulations and to avoid
going beyond socially acceptable courtesies.
(1) We will keep transparent and appropriate relationships with public officials and the
like.
(2) We will not give our business partners money, goods, or entertainment that will go
beyond socially acceptable courtesies nor receive those from them.

5. We will handle information that we obtained in an appropriate manner.
(1) We will strictly manage our trade secrets and information regarding our business
partners. We will not divulge these secrets to others, nor will we make use of these
secrets beyond its authorized intended purpose.
(2) We will strictly manage personal information.
(3) We will control confidential information obtained from people outside the company
in the same manners as we handle our corporate information.
(4) We will not infringe on intellectual property rights of third parties such as
unauthorized copying of computer software.
(5) For the purpose of investors protection, we will disclose corporate information
specified by laws and regulations of securities exchanges in a timely manner.
(6) When we gain access to certain information which could potentially have a
significant effect on stockholders decision making in stock purchase and important
information related to NADEX and our business partners, we will not engage in buying
or selling of the stocks and the like using such so-called insider information prior to the
public announcement of the information in question.
(7) We will take no part in unfair competition by gaining and making use of trade
secrets of other companies through illicit means.

6. We will make financial and accounting reports in a timely and accurate manner and
will not make use of corporate assets for illegal purposes.
(1) We will appropriately manage corporate funds and assets and use them only for the
purpose of legitimate corporate activities. We will not obtain off-the-book funds or
assets.
(2) We will always keep accuracy of financial and accounting reports and make them in
a timely and accurate manner. We will not make any false or misleading entries in the
company s books and records.

7. We will make efforts to conserve environment and conduct business activities with
consideration to environment.
(1)We will comply with applicable environmental laws and regulations and make
aggressive efforts for environmental conservation.

8. We will deal with antisocial forces and groups which threaten orders and security of
civil society in a resolute manner.
(1) If antisocial forces such as corporate extortionists and crime syndicates demand that
we carry out unjustifiable requests, we will not carelessly resolve with financial
measures but deal with them in a resolute manner.
(2)We will not engage in any business activities with antisocial forces or companies
connected with these forces.

9. We will immediately report to the company if we find activities which violate this
code of conduct.
(1) Whenever it appears that our acts may violate this code of conduct or we find acts
that violate it, we will report it to and consult with risk-compliance committee office or
internal and external persons in charge specified by the in-house information reporting
system guidelines.

Based on the recognition that establishment of the corporate governance is extremely important for improving the long-term corporate performance, Nadex makes it the basic policy to enhance the management checking function for quick and fair management decision and for keeping the transparency of the corporate management, and to promptly disclose the business status.

Understanding that we are in the age of speed and innovative changes, Nadex adopts the business management system adaptable to the age, enhances compliance, transparency and fairness, and aims at corporate governance-conscious management system.

Corporate Governance Report　 [ 472.0KB ]