Group Conduct Guidelines

6. Prohibition of Insider Trading

Specific Guidelines

1. Prohibiting trading on inside information of our Group
   1. When material information is gained regarding our Group (non-public information that may affect investment decisions), we shall take procedures according to "Internal company regulations for the prevention of insider trading" and shall neither disclose the information to any other person nor shall we buy or sell Daikin stocks until such data has been disclosed to the public.
2. Prohibiting trading on inside information of other companies
   1. Even in the event that material information regarding customers or other companies (listed companies, OTC-traded companies and the like) is obtained, we shall not disclose the information to any other person until such information has been disclosed to the public. Moreover, we shall neither buy nor sell shares of the company in question with the purpose of profiting from the inside information.
3. Prohibiting leaks of material facts
   1. When material facts of Daikin, Group companies, or other companies (listed companies) are known, we shall strictly manage that information to prevent leaks to third parties prior to public announcement that can be used for the purpose of insider trading. We shall not convey that information to parties outside those who need it to perform work.
4. Prohibiting the short-term buying and selling of stock by Daikin company officers
   1. In addition to the above, company directors, auditors, executive and associate officers must observe "Internal regulations for the prevention of insider trading" by not selling stock within six (6) months of purchase and not buying stock within six (6) months of selling stock.
   2. Furthermore, in the case of buying or selling Daikin stock, officers must follow the Financial Instrument and Exchange Law and promptly report to the Financial Services Agency.