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This code of conduct offers guidelines on matters that each and every employee should be aware of and comply with, so that the TOHO ZINC Group can operate and act as a good corporate citizen.

1. Compliance with Laws and Regulations

The TOHO ZINC Group will comply with the letter and the spirit of all Japanese and foreign laws as well as international rules. It will conduct its business operations based on fair, transparent, and free competition with integrity and social good sense. It will also maintain sound and normal relationships with the government administration.

2. Provision of Useful Products and Services to Society

The TOHO ZINC Group will meet increasingly diverse, complex, and sophisticated customer needs. It will also pay sufficient attention to energy savings, resource conservation, and environmental preservation, and will provide safe and useful products and services in an effort to earn the trust of customers and society.

3. Appropriate Disclosure of Corporate Information

As an open company trusted by society, the TOHO ZINC Group will communicate with shareholders and society in a broad manner. It will actively and fairly disclose appropriate corporate information.

4. Proactive Approach to Environmental Preservation

Recognizing that efforts to address environmental preservation are a corporate requirement, the TOHO ZINC Group will strive to establish an environmental management system and take voluntary and proactive initiatives to improve the environment.

5. Reduction of Carbon Dioxide Emissions

Recognizing that worldwide efforts to prevent global warming are a vital issue in the international community, the TOHO ZINC Group will strive to reduce emissions of carbon dioxide.

6. Balance between Biodiversity and Business Operations

The TOHO ZINC Group will aspire to balance biodiversity and business operations. When formulating business plans, it will pay attention to the impact on relevant ecosystems and local communities in and outside Japan, and will continuously practice resource recycling.

7. Social Contribution

The TOHO ZINC Group will strive to actively contribute to society as a good corporate citizen, cooperating and coordinating sufficiently with society.

8. Creation of Rewarding Workplaces

The TOHO ZINC Group will aim to make the lives of employees comfortable and affluent and provide a safe and pleasant work environment that reflects adequate consideration of the work-life balance. Concurrently, while respecting employees' characters and individualities as much as possible, it will create a corporate culture in which employees can demonstrate their creativity in a free and easy manner.

9. Confrontation of Antisocial Forces and Groups

The TOHO ZINC Group will uncompromisingly confront antisocial forces and groups that pose a threat to the order and safety of civil society and will not accept illegal or unreasonable requests.

10. Cooperation with the International Community

Guided by internationally accepted high ethical standards, the TOHO ZINC Group will not discriminate based on race, creed, religion, gender, or other discriminators. It will respect foreign cultures and customs and will manage its businesses to contribute to economic and social development in and outside Japan through business operations based on mutual trust.

11. Compliance

The TOHO ZINC Group will make the TOHO ZINC Group Code of Conduct thoroughly known to all relevant persons and encourage awareness. It will maintain an effective compliance system, including the establishment of a hotline, strive to remain continually aware of opinions and information in and outside the Company, and ensure thorough observance of corporate ethics.

12. Handling of Problems

The TOHO ZINC Group's management will set an example worth following and strive to embody the spirit of the TOHO ZINC Group Code of Conduct. Should an event occur that goes against this spirit, the management will act to resolve the problem, investigate the causes, and strive to prevent a recurrence.
Moreover, the management will promptly and accurately disclose information to society and fulfill accountability. Having clearly defined authority and responsibility, the management will severely punish those found to be involved, including themselves.

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