ACOM Group Code of Ethics and Code of Conduct

ACOM Group Code of Ethics

Enacted December 1, 2007
Amended April 1, 2020

"We, the ACOM Group, in recognition of our corporate social responsibilities and mission, and in light of our commitment to the Circle of Trust that embodies the spirit of our founders, pledge to maintain standards of conduct in accordance with the Corporate Philosophy predicated on that spirit under the ACOM Group Code of Ethics as follows.

1. We shall choose the correct course of action at all times in line with the fundamental principle of demonstrating respect for others.
2. We shall strive to improve ourselves every day, based on a full understanding of laws and regulations relevant to our work and a commitment to full compliance with same.
3. We shall adhere to the Putting the Customer First policy, respond to our customers' needs and strive to deliver the highest standards of service.
4. We shall respect the confidentiality of customer details and other information obtained in the course of our work.
5. We shall ensure that corporate information is released in a timely and suitable manner for the purpose of promoting corporate transparency.
6. As responsible members of society, we shall contribute to incarnation of sustainable society through our business activities and community programs and activities.
7. We shall strive to prevent financial crimes such as money laundering and terrorist financing while we stand firmly against the actions of any anti-social forces or groups posing a threat to public order or safety.

Code of Conduct

Enacted December 1, 2007
Amended April 1, 2020

The Code of Conduct sets out expected standards for ACOM representatives in line with the ACOM Group Code of Ethics.

1. Respect for Others

   1. Basis of Conduct

      1. ①Our conduct is predicated on respect for the fundamental human rights of our customers and all persons. We strive to act at all times in a manner befitting of ACOM representatives and of the ACOM Group as a whole.
      2. ②We shall not engage in any act that constitutes a violation of basic human rights, such as an act that could cause damage to reputation or trust or result in a privacy infringement.

   2. Fairness and Equity

      We uphold the right of all employees to be treated fairly. We shall not tolerate any discriminatory treatment at workplace and other human resources management on the basis of race, national origin, belief, religion, social status, disabilities, family origin, marital status, gender, sexual orientation, gender identity, or any other characteristics.

   3. Workplace Environment

      1. ①In order to nurture an organizational culture that encourages every employee to achieve to their fullest capabilities, we strive to create a comfortable workplace with a safe and healthy work environment while also offering a choice of employment patterns and working styles to suit different needs.
      2. ②All employees treat each other with respect and are committed to reporting, communicating, collaborating and endeavoring to promote a friendly and welcoming workplace through close communication.
      3. ③We shall not tolerate any behaviors with the potential to harm the dignity of an employee or affect motivation or morale, in particular, forms of harassment such as sexual harassment and power harassment.

2. Compliance with Laws and Regulations

   1. Compliance with Laws and Regulations

      1. ①We bear in mind that the company's existence is predicated both on strict compliance with laws and regulations, and fair and honest behaviors based on our strict code of ethics. We commit ourselves to avoid unfettered pursuit of profits at the expense of compliance in business operation.
      2. ②In all business activities, we seek to identify all applicable laws and regulations in order to ensure compliance.
      3. ③We are committed to understanding the intent and requirements of laws and regulations. We shall not seek to pursue overly literal interpretation of laws and regulations for self-serving purposes.

   2. Fairness in Corporate Activities

      In our corporate activities, we respect the meaning of fair and free competition and follow fair market rules and appropriate commercial practices.

   3. Asset Management

      We strive for proper protection and management of all the tangible and intangible assets for corporate management the Company has accumulated. We shall not tolerate any personal misuse and other behaviors that might damage these assets.

   4. Reporting or Informing Problem Situations and Seeking Advice

      1. ①We shall promptly contact and seek advice from our supervisors or the Company's whistleblowing system when we detect conduct that is against or is possibly against compliance such as the law or company regulations.
      2. ②Whether the whistleblowing arrangements are used or not, the person who receives the report, request for advice or information about any problem shall treat it in the strict confidence. The Company is committed to ensuring that reporting staff do not suffer retaliation or other negative sequences.
      3. ③When we discover any problems situations, we shall thoroughly investigate and resolve the case. Subsequently, we shall implement measures to prevent recurrence.

3. Putting the Customer First

   1. Basic Stance

      1. ①We are committed to serving the customers first and respecting the circumstances and motivations of our customers.
      2. ②We act with honesty and integrity to ensure that our conduct does not unjustly damage customer interests.
      3. ③We treat our customers with kindness, politeness and sincerity and strive to use accurate and easy-to-understand language.

   2. Provision of Products and Services

      1. ①We shall strive to understand and appreciate diversifying customer needs, plan and develop products and services that genuinely benefit our customers.
      2. ②We shall strive to acquire professional knowledge and skills to create products and services that exceed customer expectations.

   3. Information about Products and Services

      1. ①With respect to the content of products and services, we strive to provide our customers with information that is accurate and easy to understand. In particular, we pledge to keep customers well informed in advance of important procedures at the conclusion of a contract.
      2. ②We strive to avoid the use of potentially misleading or inaccurate expressions in advertising and publicity for our products and services.

   4. Complaints Procedures

      1. ①We maintain contact with our customers to encourage inquiries about our products and services, and we respond to queries and complaints quickly and properly.
      2. ②Queries or complaints from customers are forwarded immediately to the relevant department or section and used to help improve our products and services. Any inappropriate actions are promptly rectified and steps are taken to prevent a recurrence.

4. Information Management and Confidentiality Obligations

   1. Administrative Systems

      Administrative systems used for personal information, client information and information relating to corporate management are maintained in an appropriate manner in order to prevent unauthorized access, loss or alteration of data.

   2. Confidentiality Obligations

      1. ①Customer details obtained in the course of providing products and services are treated as strictly confidential and shall not be disclosed to a third party without legitimate reason or the consent of the customer.
      2. ②Personal information, client information and information relating to corporate management obtained by employees in the course of providing products and services is treated as strictly confidential, and shall not be disclosed to any third party either during the period of employment or after retirement.

   3. Insider Information

      Employees shall not engage in the sale and purchase of stocks or equivalent act explicitly for the purpose of generating a profit for themselves or other persons using important information acquired in the course of their work which is not yet in the public domain and which could potentially influence stock prices or other financial events.

5. Disclosure of Corporate Information

   1. Disclosure of Information

      We provide accurate, up-to-date and relevant information on business, financial and other matters for the benefit of shareholders, investors and customers.

   2. Accounting Practices

      We maintain appropriate accounts based on accurate records to ensure the reliability of our financial accounts.

6. Social Contribution

   1. Giving Back to Communities

      1. ①We respect the history, cultures and customs of different countries and regions around the world, and work to contribute to sustainable development of local and global communities through our business activities and the social volunteer efforts of our staff.
      2. ②We contribute to and participate in cultural, educational, sporting and other activities and provide assistance to social welfare organizations and other activities to benefit local communities.

   2. Environmental Programs

      In recognition of the importance of environmental conservation, we are committed to reducing resources and energy consumption and participating in waste reduction and recycling programs and activities.

   3. Volunteering

      We encourage and support our employees in contributing to volunteering programs.

7. Our Stance toward Financial Crime and Anti-social Forces

   1. Anti-Social Forces

      1. ①We shall resolutely oppose unreasonable demands on or interference with our business from anti-social forces and organizations such as corporate extortionists and organized crime groups.
      2. ②In the event of an unreasonable demands as per the above, the relevant departments shall coordinate their response and notify the authorities promptly.

   2. Countermeasures against Money Laundering and Terrorist Financing

      We shall endeavor to prevent illicit activities involving our products and services. We shall do everything in our power to eliminate financial crimes, money laundering and terrorist financing in particular, via thorough preventive measures.

Basic Principles in Relation to Anti-social Forces

Enacted July 1, 2009

All employees of the ACOM Group are committed to upholding our basic policy on anti-social forces as detailed below in order to maintain the integrity and security of our business operations.