I General Provisions

This Nikkiso Group Global Code of Conduct (the “GCC”) shall set internal standards of the highest level with respect to compliance. The GCC provides the basic rules that we must observe to enable us to follow our conscience and to contribute to society as corporate citizens.

II Basic Policy

We will obey the laws, regulations, our articles of incorporation, the social norms and the GCC (“laws/GCC”) in all of our business and other activities. In the event we detect a potential violation within the scope of the laws/GCC we will not condone such conduct, but will take the necessary action to deal with it.

III Scope

The GCC applies to Nikkiso Co., Ltd, (“Nikkiso”) and its group of companies (meaning the companies in which Nikkiso holds, directly or indirectly, a majority of outstanding voting shares or equity, or companies that Nikkiso substantially controls; collectively the “Nikkiso Group”), and their officers and employees (including the members of the board of directors, auditors, directors, executive officers, corporate advisors, and employees (including non-regular employees, seconded personnel, part-time employees, temporary workers, and dispatched workers).

IV Code of Conduct

1. Fair and honest business activities

(1) Free competition