Vision

Our vision is to continue to advance with vitality through imagination and embracing a world view over the next decade. We endeavor to become a timeless “One and Only” company, a pioneering institution free of limitations, capable of conducting business in an innovate, unique, and industry-leading manner.

Our devotion is to allow people to enjoy the “Dream” created by leading edge electronic technology.

Even if the electronics industry continually advances and develops, people would not enjoy technology unless it can be felt by the five senses. We continue to offer electronic products that make bridges between people and the ever-advancing electronic technologies.

For this purpose, we strive to further develop the technology that we have cultivated since our formation by procuring and maximizing the use of the finest resources at the best locations to meet the needs of our times.

Management Principles

To realize our mission, we set forth the following seven items as a basic principle of business management and activities.

1. We produce and sell electronic parts used by people throughout the world while quality, efficiency in delivery and cost competitiveness are always recognized world-wide.
2. Our directors and employees respect one another and prioritize the building of strong relationships of mutual trust with our stakeholders.
3. We operate our company with the most suitable locations and employees.
4. We adopt the principle of ability first and do not discriminate based on ethnicity, race, gender, age, belief, religion and/or physical disability.
5. We respect the manners, customs and laws of local regions in all our business activities.
6. As global citizens, we positively participate in environmental conservation.
7. We strive through innovation to develop new products while our management always envisions future generations of technology. We continually challenge ourselves to grow and strive for the better.

Commitment

We promise to our stakeholders the following commitments under our “ Management Principles”:

1. Customers

• We consider customer satisfaction perspectives at all times, and endeavor to provide products and services of high quality with speed at appropriate prices.
• We never forget the presence of our customers, and respond to their requests and questions with sincerity.
• We set “improvement of customer satisfaction” as the underlying objective to all our activities, and judge all internally proposed policies and plans by its level of contribution to this effort.
• We establish long-term and prosperous relationships with our clients, while always taking a customer satisfaction perspective.

2. Shareholders

• We fulfill our responsibilities to our shareholders by increasing corporate value through business activities, as well as by executing our dividend policy.
• We disclose our business activities and performance to our shareholders speedily and accurately.
• We respect each shareholder’s ownership and ensure to maintain fairness among them.

3. Employees

• We regard our employees as our most important resource, and strive to fully appreciate each person’s individual value.
• We aim to be a borderless, transnational corporation in a true sense; we guarantee fair treatment for our employees at all work locations, and promote teamwork among them.
• We ensure prohibition of discrimination by ethnicity, race, gender, age, belief, religion and/or physical disability.
• We assign appropriate and challenging work to employees according to their ability and evaluate and reward them properly.
• We provide employees with safe, comfortable and productive working conditions so that they can employ their abilities to the full.
• We continuously develop our human resources, encourage employees to exercise their full potential and create relationships where both the corporation and individual can grow together.
• Sumida will assist each employee in fulfilling his/her social responsibilities as a citizen.

4. Suppliers

• We aims to establish stable and friendly long-term relationships with our suppliers on the basis of mutual trust and prosperity.
• We procure optimum parts, materials, equipment, etc. based on our open door policy and on a fair and free competition basis.
• We always try to have at least one second source for the sake of risk management.
• We aim to proactively procure parts, materials, equipment, etc. from companies that have well consideration to the environment.
• Procurement is carried out in compliance with applicable laws and regulations, and under the terms and conditions set out in Purchasing Contracts.

5. Community

• We aim to grow in harmony with society through its business activities, and contribute to its development and the overall economy.
• We firmly recognize the value of corporate citizenship, and aim to become a corporation that is trusted by local communities and society by proactively addressing the local issues around us.
• We continually support the future generations in which we place our hopes through the Sumida & Ichiro Yawata Foundation.
• We uphold “Glocalization” (concurrently both global and local), and respect the practices and cultures of the communities where we conduct business.

6. Other Stakeholders

（1）Local Government/Government Institutions

• We faithfully comply with the rules and regulations of the countries and regions where we conduct business.
• We strive to establish and maintain good relations with local governments and the public sector.

（2）Industry Relations

• We maintain a good and disciplined relationship with other companies in the industry as well as industry organizations.

Code of Conduct

Sumida’s Code of Conduct is a document that illustrates our commitments to all stakeholders as a set of formal written requirements. It embodies our Management Principles and Commitment as defined that govern our corporate activities, formalizes the standards of behavior expected and requested by Sumida and sets the guidelines on how to handle various situations of business dealings.

It reminds us that Sumida is committed to acting with integrity and at the base of our integrity is a set of ethical principles that includes honesty, trust, fairness and respect for others. All of the decisions to be made and actions to be taken on behalf of Sumida must adhere to such standards of integrity and ethical behavior and must comply with all applicable laws, regulations and internal policies. The Code applies to all directors, officers and employees of SUMIDA CORPORATION, its wholly owned subsidiaries, and joint ventures in which Sumida holds a controlling interest.

1. General Standard

1.1 Respect for People and Human Rights

Sumida values its employees as the most important resource and is committed to maintaining an environment of respect for people and human rights in all business activities. We will not tolerate any discrimination on the basis of ethnicity, race, gender, age, belief, religion and/or physical disability.

1.2 Ethics and Business Integrity

Sumida is committed to conducting all business with integrity, in accordance with its business ethics. In our activities, we have our own business principles, that is, pursuit of customer satisfaction, respect for safety, proper environmental management and contribution to the social and economic development of the regions in which we do business, so that we can always ensure trust from all people and societies.

1.3 Compliance with Legal Requirements and Company Policies

Sumida conducts its business activities in a global and diverse environment. We strive to understand and respect diversity and difference of cultures and customs, and comply with all applicable laws and regulations of each country and region in which we operate. All directors, officers and employees of Sumida are requested to comply with all applicable laws and regulations as well as internal company rules and policies with regard to their business activities. All parties are responsible to understand the necessary requirements as applied to one’s job. In performing these duties, the Compliance Officer, Legal Department, Internal Auditor and Risk Management Officer are available to provide advice and support to all.

1.4 Commitment to Sincere and Responsible Behavior

All directors, officials and employees are requested to be sincere, reliable and prompt in performing their duties, to contrive to improve operations for rationalization and higher efficiency, and to work with optimum use of physical and intellectual ability in cooperation with others.

2. Employment

2.1 Equal Employment Opportunities

Sumida is committed to providing equal opportunity to all employees and applicants in hiring, training and development without regard to ethnicity, race, gender, age, belief, religion and/or physical disability.

2.2 No Forced Labor/Child Labor

Sumida uses neither form of forced, involuntary, nor child labor (the term ‘child’ is defined in accordance with the laws of each country or region which stipulate the youngest acceptable age for labor).

2.3 Sound Labor and Employment Practices

Sumida is a transnational company and so we guarantee fair treatment to our employees without regard to their location of work. Teamwork is highly promoted among all employees. We strive to create and maintain a sound, safe and productive environment which is free from discriminative conduct that may result in a hostile atmosphere, so that employees can exert their ability to its full degree. All directors, officers and employees will make an utmost effort to create a fair and sound working environment as well as comply with all applicable laws, regulations, internal rules and policies.

3. Business Integrity

3.1 Prompt Response and Obligation to Notify

In addition to its commitment to daily business activities, Sumida is also committed to responding sincerely, promptly and appropriately to those business and work related emergencies, accidents, irregularities and unexpected events that could be damaging or unbeneficial to our customers or Sumida. All directors, officers and employees are requested to adhere to their obligation to ensure that appropriate action is taken to prevent insincere conduct, inaccurate records, false reporting, etc.

3.2 Gifts and Entertainment

Sumida is committed to conducting business with integrity and fairness and avoiding all unfair and improper dealings. While bribery is a serious criminal offence in many countries, even under circumstances where it is not explicitly prohibited by local law, it is our policy to prohibit any director, officer or employee from making gifts of cash value to our customers, business partners, relevant government officials or other concerned individuals concerned for the purpose of influencing any business activity. The acceptance of cash, gifts or entertainment that may have undue influence to our business decisions is also prohibited. All directors, officers and employees accordingly are committed to abiding by all applicable laws and regulations in each country and region, as well as the internal company rules and policies with regard to their individual business activities.

3.3 Free Competition and Fair Commercial Transaction

Sumida is committed to compliance with all applicable antitrust, competition and fair trade laws, policies and treaties of each country and region in all its business activities and it is prohibited from any conduct restricting competition or unfair business dealing. All directors, officers and employees must know, understand and comply with these laws and are requested to consult with the Compliance Officer or legal council if they are not certain in connection with the legitimacy of business arrangements.

3.4 The Protection of Intellectual Property Rights and Confidential/Personal Information

3.4.1 Compliance of Laws and Regulations & Internal Rules of Each Sumida Company

1. （1）All directors, officers and employees are expected and directed to comply with the Law on Protection of Personal Information, and all other applicable laws and regulations with regard to Information Security Management in each country as well as the internal rules of Sumida.
2. （2）All directors, officers and employees should recognize the importance of patent right, trademark right, copyright or other intellectual property rights, and are prohibited from infringing such rights.
3. （3）All directors, officers and employees should recognize that when they cause any damages to a third party by unauthorized leakage of business information, not only will Sumida suffer the cost of such damages but the responsible person may undertake further obligation to compensate such damage to the company.

3.4.2 Secure Management of Customer Information

1. （1）All directors, officers and employees are prohibited from misusing or making illegal copies of particular customer information or any information entrusted by a customer (“Customer Information”) without permission.
2. （2）All directors, officers and employees are expected and limited to disclosing Customer Information only to those who are permitted to use such information.
3. （3）All directors, officers and employees are expected and directed to manage and treat Customer Information appropriately complying with the “Trade Secret Management Policy” which sets out information management procedures.

3.4.3 Protection of Personal Information

1. （1）All directors, officers and employees should respect the private information of individuals such as customers, employees of material suppliers, business partners and themselves; and are requested to appropriately protect such information.
   All directors, officers and employees are expected and directed to manage and treat personal information strictly complying with the “Personal Information Management Policy” which sets out information management procedures.

3.5 Recording and Reporting of Accurate Information

All directors, officers and employees are requested to create and maintain all company documents or records such as financial statements to reflect the business activities accurately and fairly. They are also requested to cooperate fully with our internal and external audits or investigations which are conducted in respect of the compliance status and to make accurate reports based on facts.

4. Ethical Personal Conduct

4.1 Insider Transactions

Insider transactions (insider trading, insider dealing and stock tipping) are criminal offenses in most countries where Sumida does business. Insider trading or dealing means personally buying or selling stocks or other securities of any company while in possession of material or price-sensitive non-public information (inside information) about a company through their work. Stock tipping means disclosing inside information about a company to another person such as a relative, colleague or friend that enables that person to buy or sell stock or other securities of the company for a profit on the basis of such information.

Sumida has established standards of conduct for our employees and others who obtain inside information through their work for Sumida. All directors, officers and employees are required to strictly comply with applicable laws as well as the “Rules for Regulation of Insider Trading and Control of Inside Information” which sets out internal policies and procedures for information management and proper dealings that request them to refrain from trading Sumida stock at certain times and under certain conditions. Nonetheless, these policies and procedures are not meant to restrict the freedom of employees to make appropriate personal investments, or each company's right to legitimately use and disclose inside information in the ordinary conduct of its business.

4.2 Conflict of Interest

All directors, officers and employees should avoid any situation which may lead to an actual or perceived conflict of interest with Sumida. All business activities must be conducted in accordance to the objectives of Sumida, and all business decisions must be made ensuring that any situation which may impair or appear to impair the independence of our judgment is avoided. When such a situation arises, they are required to disclose the relevant information to their supervisors and the Compliance Officer in writing in accordance to the applicable internal policies, and obtain prior authorization before engaging in any further business activities.