Code of Conduct

7. Operating System

(1) Establishment, Revision and Abrogation

The establishment and any revision or abrogation of the SII Code of Conduct will be approved by the president of SII after deliberation by the SII Compliance Committee.

(2) Application to SII Group Companies

For each SII group company, its representative shall decide to adopt the SII Code of Conduct as the company’s code of conduct and shall apply it to the company’s directors/officers and employees.
Any SII group company may make an addition or change to the SII Code of Conduct upon its representative’s approval if such addition or change is necessary due to applicable laws and regulations or the custom of the country or region or due to the company’s business activities, unless such addition or change would create any provisions contradictory to, or less restrictive than, the corresponding provisions of the SII Code of Conduct. Any change or addition to the SII Code of Conduct must be referred to the SII’s Compliance Department in advance.

(3) Familiarizing Employees with This Code

SII’s Compliance Department shall be responsible for familiarizing all directors/officers and employees with the SII Code of Conduct. Each director/officer and supervisor shall provide guidance and supervision to ensure that all employees in his/her charge comply with the provisions of the SII Code of Conduct. If any employee violates the SII Code of Conduct, his/her supervisor shall immediately report it to the compliance department and conduct investigation of such violation as well as taking measures necessary to eliminate consequences and prevent recurrence.

(4) Reference

We strive to clear any doubt as to any provisions or interpretation of the SII Code of Conduct by referring it to SII’s Compliance Department.

(5) Sanctions

Any person who violated or ignored any violation of the SII Code of Conduct will be subject to sanctions in accordance with the working regulations and to other discipline in terms of personnel evaluation and treatment, depending on the nature of the violation.

Revised and effect on April 1, 2006