AJ

Code of Ethics

Preamble The AJ shall treat happy management, customer satisfaction, social responsibility and corporate ethics as primary values based on a pioneer spirit as the standard for all of its business operations and conduct business in a transparent and fair manner. Through free and fair competition, the AJ will perpetually grow into an ultra-leading corporation that grows and shares values with customers, employees, partner companies and the nation, as well as the regional community, based on mutual trust. In this connection, the AJ hereby sets forth Code of Ethics for right conduct and value judgments which every employee should abide by in order to realize ethical management surpassing the rules imposed by the law or government regulations, and pledges to implement them.

Chapter 1 Customer-oriented operation

The AJ coexists with its customers, and by realizing that the customers are the true foundation of our business, we shall always respect them and meet their expectations by ceaselessly creating and providing value.

1. Customer respect

We shall consider the customer’s opinions as the foundation for the company’s growth, pay attention to their voices at all times and treat them as the primary value for all determination and conduct.

2. Value creation for customers

① We shall provide the best quality and service instead of product or service oriented towards the company’s survival, so that customers will be satisfied and impressed with our product and service to truly feel the AJ’s values.

② We shall seek the AJ’s development in the process of continuously creating value that gives assistance and satisfaction to the customers of the AJ.

3. Customer satisfaction

① We shall not only provide the best quality and service that meet customer’s demands, but also accept customer’s comments and suggestions with an open mind.

② We shall resolve customer dissatisfactions and disputes quickly and rationally and treat all customers in a fair manner.

③ We shall always keep our promises with our customers, and make our best efforts for smooth communication.

④ The AJ shall inspire the customers with satisfaction by always creating novelty.

Chapter 2 Ethical management

Through ethical management complying with fundamentals and principles, the AJ shall protect the customers’ property and honor, and by also complying with all laws in the countries/regions where it conducts business and building trust with partner companies through fair means and good faith competition, we shall promote mutual development with all competitors.

1. Ethical business

① We shall not conduct business using unfair means that take advantage of loopholes in the law, or through unfair means that deviates from principles, and we shall not violate commercial ethics.

② We shall break down existing unfair and unequal systems and customs such as collusion, etc., and adhere to fundamentals and principles, and through fair and good faith competition, we shall work towards establishing the principles of free competition.

③ We shall not hinder free competition by unfairly taking advantage of the weaknesses or information of another party or by engaging in unethical behavior, and through good faith competition, we shall promote mutual trust and development.

2. Fair trading

① We shall defuse all unfair competition that violates commercial ethics and unfair conduct and shall grant fair opportunities to all businesses.

② All transactions shall be conducted through a legal and fair procedure, and we shall not engage in any unfair conduct using our dominant position.

③ We shall guarantee fair opportunities and reasonable conditions for partner companies, thereby promoting cooperative relationships as a partner.

④ We shall recognize the development of partner companies as our own and shall actively provide support for them to become more competitive and grow further through continuous innovation, and create an atmosphere for clean transactions.

Chapter 3 Basic ethics of executives and employees

The AJ’s executives and employees shall establish the right values that are in compliance with fundamentals and principles based on honesty and diligence. Also, we shall complete our given mandates through endless self-development and innovation and conduct all operations transparently, fairly and reasonably by taking ethics as the primary value.

1. Basic ethics

① The executives and employees shall have pride and dignity as members of the AJ and shall bear in mind that their conduct represents the AJ, and always have an honest and fair attitude.

② The executives and employees shall place all their business activities within the scope of the Code of Ethics, and by establishing high ethical values, they shall strive to enhance the honor of individuals and the AJ.

③ The executives and employees shall form business and human relationships that surpass the ranks and sexes and pursue their own growth and the AJ’s development.

2. Completion of mandate

① The executives and employees shall share the management philosophy and vision of the AJ, and shall diligently perform their respective mandates in accordance with the objectives and values pursued by the AJ.

② The executives and employees shall perform work with utmost effort not through any unethical or unfair means, but through justified means.

③ The executives and employees shall make their best effort to perform their functions and process them in a reasonable manner by understanding relevant regulations and systems related to work at all times.

3. Autonomous performance of work and sense of responsibility

① The executives and employees shall conduct the duties and work granted to them based on an audacious spirit and creative thinking and shall be independently responsible therefor.

② The executives and employees shall predict and manage the risks that may be incurred as a result of work performance through transparent decision making, and shall be responsible for problems incurred.

③ The executives and employees shall empathize with the company’s common objectives and values and pursue endless self-development for better value creation.

4. Fair performance of work

① In performing work, the executives and employees shall strictly distinguish between personal and business matters and shall not engage in conduct based on personal emotions that hinders the company’s benefits.

② The executives and employees shall perform their duties in a fair manner under the given rights and responsibilities, and shall not engage in conduct such as abusing one’s authority, or falsifying or exaggeration for personal gain.

③ The executives and employees shall not accept or allow briberies in forms of money or other favors, etc. that would interfere with the fair performance of duties.

④ The executives and employees shall not engage in any conduct that goes against the rule of law or commercial order in performing the duties or any unethical conduct.

5. Prohibition of monetary transactions

① The executives and employees are prohibited from engaging with one another in conduct such as giving presents, etc. and such conduct shall be strictly prohibited.

Provided, however, that exceptions may apply to the extent allowed under instructions.

② The executives and employees are prohibited from engaging with one another in loaning cash or joint guarantees.

6. Healthy and harmonious organizational culture

① The company shall respect individual creativity, and by providing equal opportunity for fair competition, shall create a forum for self-realization. Also, the executives and employees shall not spread baseless rumors or engage in discourteous behavior by mutually respecting each other.

② The executives and employees shall respect each other’s personal lives to form a common consensus where autonomous suggestions, proposals and complaints can be expressed, thereby making a more harmonious organizational structure.

③ The executives and employees shall not discriminate against one another for reasons unrelated to work, such as blood ties, regional ties or school ties, and shall not form any private cliques which create discord within the organization or damage sound organizational culture.

④ The superiors shall not order their subordinates to engage in any personal matters unrelated to work or any wrongful work.

⑤The executives and employees shall not engage in any speech that damages the good morals and customs or good co-worker relationships or engage in sexual harassment that induces sexual humiliation.

⑥ The company shall provide support so that the executives and employees can form human relationships through free leisure and hobby activities, and shall ensure that such activities and meetings work as a foundation that enhances work efficiency and improves the quality of personal lives.

Chapter 4 Basic ethics of partner companies

The AJ and partner companies shall build trust through fair and rational corporate activities, recognize each other as partners that share the values of mutual coexistence and co-prosperity, and maintain the honor and integrity to pursue the sound development of corporate culture together.

1. Basic ethics

① The partner companies shall share the growth and value along with the AJ, and shall make efforts to maintain the other company’s honor.

② The partner companies shall make efforts to actively participate in the implementation of the AJ’s Code of Ethics, thereby making efforts to create an atmosphere for sound and fair transactions, and shall not provide any money, entertainment or favor in any form that is unethical or immoral to the AJ’s employees.

③ They shall not engage in any conduct that damages the trust relationship with the AJ, including disparaging other partner companies or spreading baseless rumors.

④ The AJ shall form a sense of unity by considering the partner companies from the position of a partner in corporate activities, and give a stable sense of trustworthiness by paying proceeds as contracted.

⑤ The partner companies and the AJ shall engage in business activities based on good will, and shall promote joint profit and growth as business partners.

2. Fair and responsible performance of work

① By sharing a sense of the objectives, vision and values of the AJ, and by having a sense of responsibility by realizing that the AJ’s development is the partner companies’ development, the partner companies shall perform in good faith the work and duty granted to them.

② The partner companies shall perform the granted work or duties in accordance with legal processes in a fair and diligent manner, and by complying with the laws related to work, the company’s regulations and system, they shall not engage in any immoral or unethical conduct that could be socially criticized.

3. Securing competitiveness

① The partner companies shall realize that safety as well as production activities are also the greatest task in securing competitiveness and shall make endless efforts to prevent accidents by raising the awareness of all workers and through compliance with safety rules.

② By endlessly developing technology, they shall procure competitiveness in the price of raw materials and technology and make their best efforts to raise competitiveness.

4. Information and security management

① The partner companies shall protect the AJ’s intellectual property and trade secrets as well as comparable business knowledge, shall prohibit all conduct that infringes upon them, and shall not disclose the company’s secrets, etc., to third parties.

② The partner companies shall not disclose the company’s credos, regulations, instructions and technical documents without permission.

Chapter 5 Responsibility towards nation and society

The company’s economic activities are not merely to provide products and services to the market, but also to contribute to the development of the national economy and local community through rational corporate activities. It therefore has the responsibility to create profits through continued growth and development.

1. Social responsibilities and duties

① We recognize that the corporation’s social liability includes voluntary social contributions and services and shall actively contribute to the development of the local community and cultural development.

② We shall place a priority on the safety of the residents in the place of work and shall not engage in illegal or immoral conduct. Also, the executives and employees shall make efforts towards local community activities, thereby forming a sense of unity between the corporation and the local community.

③ We shall uproot unethical and immoral conduct that damages healthy and fair corporate activities and conduct in good faith the duty to pay taxes and other obligations imposed by the nation and local governments.

2. Environmental protection

① We shall not damage the surrounding facilities or the environment of the operation site so that local community residents can enjoy a pleasant living environment.

② In order to protect nature and prevent environmental pollution, we shall make our best efforts to prevent pollution.

Addendum

Article 1 [Effective date]

These Code of Ethics shall become effective from May 27, 2008.

Article 2 [Ethical guidelines]

Ethical guidelines shall be separately established and implemented to ensure that the executives and employees comply with the Code of Ethics in a more strict manner.

Article 3 [Relationship with other regulations]

These Code of Ethics shall prevail over any other regulations of the company for implementation and interpretation.