Code of Ethics

HORIBA has drawn up its Code of Ethics comprised of eight articles (1. Compliance, 2. Excellent products and services, 3. Healthy relationship with governments, 4. Creation of a rewarding workplace, 5. Respect for human rights, 6. Engagement with stakeholders, 7. Environmental protection, and 8. Crisis management) as further introduced below. This is in compliance with the company motto of “Joy and Fun” and our HORIBA Corporate Philosophy. All HORIBARIANs (board members, officers and employees of the HORIBA Group, hereinafter collectively referred to as “us” or “we”) are expected to strictly observe them in order to constantly be aware of our mission and role as well as to pursue sustainable development into the future as a global enterprise.

1. As a "good corporate citizen," we shall comply with laws, regulations, the articles of incorporation, and widely accepted social norms.

We shall carry out our business in compliance with laws (including but not limited to competition law, anti-corruption law, intellectual property law, security trade law, securities regulation and various business laws), regulations, articles of incorporation and widely accepted social norms, and shall not pursue profits by using unethical means such as cartels and bribes.

2. We shall contribute to society by providing excellent products and services.

2.1 Encouragement of research and development
We shall create new products and businesses based on a spirit of bold originality and ceaseless diligence. By doing so, we shall improve the quality of life of people around the world and contribute to favorable development of social issues. We shall devote our expertise and technology to the development and advancement of the welfare of humanity, and we shall not conduct unethical research and development.

2.2 Implementation of responsible procurement activities
We shall remember that we build business activities based upon the support and cooperation of our suppliers who provide us with raw materials, parts, and services used in production, and of those who support us in other ways. We highly value the trusting relationship we have established with our suppliers and engage in fair and transparent transactions.

2.3 Promotion of production
We shall commit ourselves to daily production activities to fulfill our mission as a producer who develops high quality products that are truly useful, produces such products as efficiently as possible, and supplies them in a timely manner and at appropriate prices.

2.4 Ensuring of product safety
We shall ensure product safety throughout all work processes so that our products may be worthy of our customers’ trust.

2.5 Establishing good, fair relationships with customers
We shall always endeavor to provide high quality products and appropriate services in order to increase customer satisfaction and earn our customers’ trust. We shall also work to contribute to society through fair and free market price competition. To realize this goal, we shall engage in fair sales activities being aware that each of us is a representative of the company.

3. We shall maintain sound and normal relationships with governments.

We shall understand that fairness and justice in relationships between companies and politics and government agencies is strongly required by laws and regulations, especially regarding the prohibition of the provision of unfair profits or bribery, and we shall comply with relevant laws and regulations diligently.

4. We shall aim at creating a rewarding and comfortable workplace.

4.1 Realization of an open and fair working environment
We shall endeavor to realize an open and fair working environment that allows each employee to work for the achievement of our management goals while maximizing his or her potential. In order to do so, we assess their accomplishments by noting positive points; this serves as the core of our various systems for evaluation, compensation, and education, and we shall build diverse human resource and employment systems that encourage employees to challenge themselves to improve their personal abilities individually.

4.2 Promotion of physical and mental wellness
We shall promote physical and mental wellness and achieve a work-life balance. Thus, we shall comply with laws and regulations regarding payment of appropriate wages, management of working hours, and provision of holidays and vacations. We shall also respect religious practices and give consideration to employees who need special facilities.

4.3 Ensuring of a safe working environment
We shall place the highest priority on ensuring the safety of all people involved in all of our business activities. To this end, we shall observe internal regulations, rules, and operation standard sheets as well as relevant laws and regulations.

4.4 Respect for privacy
We shall respect individual privacy, and shall exercise the utmost caution in handling and appropriate management of personal information.

5. We shall have respect for human rights of all people

5.1 Elimination of discrimination
We shall secure a healthy workplace which is free of harassment and discrimination based on race, creed, skin color, gender, religion, nationality, language, physical characteristics, property, hometown, etc. in the case of recruitment, placement, education, rewards, promotion, etc. of employees. We shall also forbid sexual harassment as well as abuses of one’s position or authority in the workplace (workplace bullying) and any other harassments.

5.2 Respect autonomy in labor activity
We shall not tolerate child labor, forced labor, debt labor or human trafficking. All labor activities are undertaken willingly and we shall accept requests to terminate employment in accordance with the standards established by the relevant laws and regulations of each country and region.

5.3 Respect for basic labor rights
We shall respect basic labor rights, including workers' rights to organize and bargain collectively.

5.4 Implementation of measures for remedies and prevention of recurrence
In the event a problem related to violation of human rights occurs, we shall promptly investigate the matter and take strict measures to assist the victims and prevent recurrence.

6. We shall disclose information appropriately and strive for active dialogue with stakeholders

6.1 Promotion of public relations
We shall strive to raise awareness and enhance the value of our brand by widely disseminating information concerning our management policies, products, technology, and other activities through our public relations efforts. We shall aim to promote sales and develop business by increasing people’s affection for and trust of HORIBA brand.

6.2 Information disclosure and prohibition of insider trading
We shall disclose information truly needed by society, except corporate secrets and contractual confidential information, in a timely and appropriate manner.

6.3 Active contribution to society as a "good corporate citizen"
We shall maintain good relationships with society through close ties and collaboration. In the event of the occurrence of a disaster, we shall actively conduct rescue and disaster management activities in close cooperation with local communities. In addition, we shall respect the concept of universal design, which is aimed at making products accessible to as many people as possible, and we shall work to realize it.

7. We shall voluntarily and actively commit ourselves to environmental issues

By bearing in mind that we benefit tremendously from the earth such as its resources and energy necessary for our business activities, we shall make the utmost effort to minimize the environmental burden imposed by our business activities and the products and services we offer, so that we shall pass on to the next generation a global environment in better condition. We shall also observe environment-related laws and regulations and actively engage in improvement activities aimed toward global environmental conservation.

8. We shall enforce crisis control by rejecting any connection with violent antisocial forces, promoting information security, and being prepared for terrorist attacks, natural disasters and spread of infectious diseases

8.1 Rejection of any connection with antisocial forces
We shall avoid all involvement with any individuals or organizations that adversely affect the public order or impair healthy corporate activities (i.e. violent antisocial forces).

8.2 Promotion of information security measures
We shall endeavor to raise awareness of information security, recognize that cyber security is one of the risks that have a significant impact on management, and take appropriate safety management measures according to the risks. We shall also thoroughly manage confidential information acquired in the course of our business activities.

8.3 Crisis control
We shall establish a crisis management system to understand, analyze, prevent and respond to risks related to corporate activities of the entire group, in order to prevent risks of damage such as originating in terrorist activities, natural disasters, and the spread of infectious diseases and we shall work to minimize damage. If necessary, we shall cooperate with various stakeholders such as business partners, other companies, and industry groups to minimize damage to society as a whole.

(Established on January 26, 2021)