Supply Chain CSR Promotion Guidelines

7. Prohibition of insider trading

Specific Guidelines

1. Do Not Take Part in Insider Trading Based on Your Company’s Internal Information
   When material information (non-public information that may affect investment decisions) is gained regarding your company and its group companies, strictly manage such information in order to prevent leaks to third parties prior to public disclosure, and ensure that none of your employees buy or sell shares in your company for the purpose of profiting from the insider information.
2. Do Not Take Part in Insider Trading Based on Other Companies’ Internal Information
   When material information is obtained on suppliers and other third party companies in the line of duty, strictly manage such information in order to prevent leaks to third parties prior to public disclosure, and ensure that none of your employees buy or sell shares in the company in question for the purpose of profiting from the insider information.
3. Prohibit Leaks of Material Facts
   When material facts of your company and its group companies, as well as other third-party companies (listed companies), are obtained, strictly manage that information prior to its public disclosure to prevent it from leaking to third parties and being used for the purpose of insider trading. In addition, do not convey that information to parties other than those who need it to perform work.