Chugai’s corporate philosophy is that “human growth is the basis of the Chugai management mindset.” With this in mind, we have taken great pleasure in contributing to industry and society through the “creation of communication activities that have value.”

It goes without saying that our corporate activities are the accumulation of the actions of each and every one of our employees. However, in order to realize our corporate philosophy and to be widely accepted by our customers and society with trust and goodwill, we believe that it is of utmost importance that all employees comply with laws and regulations, adhere to company rules, respect social norms, and act in accordance with corporate ethics.

In addition to systematically developing compliance structures, we have also created the “Chugai Compliance Code of Conduct”. The Code of Conduct is comprised of four areas that each and every one of our employees should adhere to in their behavior to realize our corporate philosophy: “Fair Dealing,” “Proper Handling of Information,” “Compliance with Laws and Regulations in Marketing and Communications,” and “Maintenance of a Pleasant and Orderly Workplace Culture and Sound Relationship with Society.”

We hereby declare that all of our officers and employees fully understand these objectives, will place the highest priority on compliance in all aspects of our daily activities and will properly respond to the trust of our customers.

Chugai Compliance Code of Conduct

1. Fair Dealing
   We will respect fair and equitable transactions and will refrain from taking advantage of our superior position and from conducting business in violation of the Subcontracting Act. (Subcontracting Act)
   We will strive to promote fair and free competition and will not engage in cartel activities or unfair transactions. (Antimonopoly Act)
   We will maintain sound relationships with public officials and politicians, and will not engage in bribery or other illegal or unfair behavior. (National Public Service Ethics Act)
   We will comply with all tax laws and accounting standards and will not engage in any improper accounting practices.
   We build sound business relationships with ov
2. Proper Handling of Information
   In compliance with the Personal Information Protection Act, we recognize that our business activities may involve the risk of personal information leaks, and therefore implement strict management and prevention measures in accordance with the Chugai Privacy Policy. (Personal Information Protection Act)
   As an advertising company, we are aware that we handle new product information of our advertisers and important information from various companies, and that our business has many opportunities to come in contact with the press. We will therefore ensure thorough information management and properly manage confidential information. (Unfair Competition Prevention Act)
   We will not engage in insider trading based on undisclosed material corporate information. Additionally, we have established internal rules to prevent the occurrence of such issues. (Financial Instruments and Exchange Act)
3. Compliance with Laws and Regulations in Marketing and Communications
   We recognize that the production of advertisements and tools is a job in which many rights are managed. We will therefore comply with intellectual property rights including copyright laws, trademark laws, and patent laws. We also recognize that advertising is a job that makes use of language and design. We will therefore also familiarize ourselves with the laws governing advertising and seek to carry out fair and accurate communications activities. (Copyright Act, Trademark Act, Food Sanitation Act, Pharmaceuticals Act)
   In promotion planning, we will pay close attention to the regulations on premiums during campaigns, labeling of advertisements, and compliance with the Product Liability Act. (Act Against Unjustifiable Premiums and Misleading Representations, Product Liability Act)
   In planning events, we will comply with the Outdoor Advertisements Act, the Act on Waste Management, and other environmental ordinances. We will properly check all local environmental regulations in the areas in which we organize events and properly handle any waste with due consideration for the environment. (Outdoor Advertisements Act, Act on Waste Management, Environmental Ordinances)
4. Maintenance of a Pleasant and Orderly Workplace Culture and Sound Relationship with Society
   We regard human growth, as stated in our Management Philosophy, as the basis of Chugai’s management mindset. We will ensure that people and human growth are the foundation of our management. We seek to create a healthy workplace culture by complying with fundamental human rights and other laws and regulations pertaining to human rights.
   Through growth, we will create valuable communication activities, contribute to society, and strive to maintain healthy relationships with society.
   We do not tolerate any acts that violate human rights, such as sexual harassment, power harassment, and violent acts within the company.
   We understand and follow internal rules, beginning with work rules. (Human rights protection laws including the Constitution) (Work rules)

April 1, 2008
Chugai Co., Ltd.