Anritsu Group Code of Conduct

1.1 Essence of Anritsu Group Code of Conduct

• To increase corporate value of a company, it is essential for all the employees, including managements (hereinafter “we”, “us”, and “our”), to truly realize the social responsibility of the company, abide by relevant laws and regulations in every aspects of corporate activities, and to act in accordance with the social ethics. This Anritsu Group Code of Conduct (hereinafter the “Code”) provides the guideline of conducts which we should bear in mind in our daily business operation, aimed to assure that Anritsu Group is consistently being an ethical corporate group.
• This Code exemplifies fundamental ethical views and typical corporate guidelines, but does not cover all the circumstances that may arise. In each individual situation, we should judge “Fairly”, and act with “Sincerity” by fully understanding relevant laws and the spirit of this Code.

1.2 Basic Attitude

• This Basic Attitude provides the fundamental mind-set as a member of Anritsu Group in conducting corporate activities. We should keep this mind-set to pursue corporate activity based on “Sincerity, Harmony, and Enthusiasm”, comply with each specific provision of this Code later described in chapter 2.
• We will promote fair and sound corporate activities by observing applicable laws, this Code, and company policies along with corresponding fundamental policies and manuals.

1. We will respect each and every person's human rights and will not discriminate or impair personal dignity. Moreover, we will not allow any forced labor or child labor.
2. We will contribute to the development of the international community and the local community by respecting its customs and cultures.
3. We will proactively address environmental issues such as climate change and contribute to the creation of a future that is friendly to people and the earth.
4. We will earn satisfaction and reliability by providing products and services that are useful to society and by giving due consideration to the quality, safety, and environment.
5. We will engage in fair, transparent, and free competition, maintain a healthy relationship with politics, government, citizen, and organizations.
6. We will improve transparency of corporate activities by disclosing business information fairly and in a timely manner.
7. We will properly manage personal information and information assets including customer information.
8. We will act sincerely with responsibility, awareness, and integrity, continually improve corporate culture of the organization as a member of the Anritsu Group.

1.3 Observance Responsibility

• We shall sincerely implement the guidelines set forth in this Code. Executive officers and managements shall, at all times, advise employees to abide by this Code and keep higher ethics and awareness to abide by the laws to serve as a model for all the other employees.
• In order to take concrete action in accordance with this Code, Anritsu Group (each company) should continuously develop educational and enlightenment campaign by reinforcing the company regulations, manuals, etc.
• Disciplinary action shall be taken when your action is in violation with this Code and falls under the grounds for such action stipulated in the company employment regulation. Furthermore, when your intentional or negligent action cause damage to Anritsu, you may be personally liable for the damages.

2.1 Respect of Human Rights

• We will respect every person's human rights, eliminate prejudice, and will not discriminate depending on race, nationality, religion, creed, sex, sexual orientation, gender identity, age, social status, or disabilities whether mental or physical.
• We will respect each and every individual's personality, individuality and diversity, and will not accept any discriminatory languages or behaviors, sexual harassment, or any kind of harassment which would result in hurting other people's personality.
• We will develop deeper understanding and act towards human rights respect through various educational programs.

2.3 Maintenance of Safety and Health, Working Environment

• We will comply with laws and regulations concerning occupational safety and health, and strive to create a safe, secure, and hygienic working environment.
• We will strive to improve the moral and manners necessary to conduct our business and create a disciplined working environment.
• We will strive to maintain sound communication and create a comfortable working environment in order to perform our business.

2.4 Healthy Work Style, Promotion of Work-Life Balance

• We will strive that each employee maintain and promote mental and physical health, and keep work-life balance to maximize his or her potential.
• We will comply with labor-related laws and regulations, manage our work appropriately, and avoid overwork and long working hours.

3.1 Relation with International Society and Community

• We will abide by the international rules and laws of each country we do business with, respect their cultures and customs as well as cooperate with the international society and development of the local community.
• We will contribute to the local development by cooperating with the local community.

3.3 Contribution, Political Contribution, Political Activity, etc.

• We will sufficiently consider the necessity and validity, abide by relevant laws and regulations when we decide to make donations as part of our social contributions.
• We will abide by relevant laws and regulations concerning politics, election, or political activity when we deal with these activities.
• We will not use the company's facilities, name, or position in the company for political activities conducted in our individual capacity.

4.3 About Procurement

• We will observe laws and regulations relevant to material purchasing, and will practice fair trade as well as purchase materials and services at an appropriate quality, price, and delivery time.
• We will conduct our material purchasing based on sound commercial practices and strive to work together with our business connections for mutual harmony and benefits. We will not abuse our dominant bargaining position over our business connections, or seek any personal benefit relating to work.

4.4 Observance of Antimonopoly Law etc.

• We will conduct fair business activities by observing laws and regulations relevant to promotion of fair trading such as Anti-Monopoly Act.
• We will not engage in any activities such as bid rigging or cartel which restricts fair and free competition, or any activities which might be considered as us been engaged in such activities.
• We will not practice exclusion of distributors etc., unjust discriminatory treatment, or any type of unfair transaction such as restricting business activities.
• We will support distributors etc. handling Anritsu Group's products and services to conduct appropriate activities in compliance with laws and regulations.

4.6 Disclosure

• We will make every effort to gain proper understanding and acceptance from the society by broadly communicating Anritsu Group's company philosophy, company vision, and company policy.
• We will make timely and accurate disclosure of Anritsu Group's business information to stockholders, investors etc., in accordance with the relevant laws and regulations.

4.7 Advertisement Activities

• We will improve our understanding and trust from the customers by improving brand value of Anritsu and Anritsu products through advertisement activities based on the company philosophy, company vision, company policy, and the business strategy of Anritsu Group.
• We will not allow inaccurate display or expression that might lead to false recognition of Anritsu Group's products and services.

4.8 Correspondence to Entertainment and Gifts

• We will maintain moderation and comply with the internal policies and procedures, sound business customs, and social norm on business entertainment, giving or receiving gifts from business connections.
• We will not bribe, provide illegal payoffs, or provide any type of offerings without reasonable grounds to any type of public officials including foreign public officials.

5.1 Proper Accounting and Operating Processing

• We will perform proper accounting abiding by relevant laws and internal policies and procedures.
• We will accurately prepare and properly save all the various records of finance and accounting. We will not perform improper accounting or any other means which would cause damage to the company.
• We will comply with the tax laws and regulations or rules of each country and make appropriate tax payments.
• We will develop and operate an internal control system for the proper execution of business and the accurate and appropriate recording of each and every transaction.

5.4 Management of Information

• We will properly protect and manage information assets including Anritsu's trade secret, abide by laws and company regulations concerning information.
• We will not disclose, falsify, or make fraudulent use of our trade secret either during or after the term of employment.
• We will respect trade secrets of third party's including customer, business connection, or competitor, and will not obtain or use information illegally, or use other than the purposes as intended.

5.5 Proper Use of Information System, Social Media

• We will properly utilize information system and protect from leaking company's trade secret, personal information, and information provided by the customers.
• We will use and manage personal computer and other equipment provided by the company in accordance with the company procedures to prevent from any theft or loss.
• We will not use our personal private computer or any other electronics to conduct our work to keep unintended disclosure of business information, unless otherwise permitted in accordance with each region's internal rules.
• We will not use Anritsu's network for personal trading (stock, auction or the like) or visit internet sites containing inappropriate contents.
• We will recognize the convenience, benefits, and risks of using social media, and comply with the rules established by the company upon use.
• We will not transmit information over the internet or intranet which would degrade company image and credibility, any false accusation to others leading to discrimination.

5.7 Protection of Intellectual Property Rights

• We will proactively engage in creative activities to strengthen our intangible assets. We will also expand, strengthen, and protect intellectual property rights by utilizing those rights of our company.
• We will observe laws related to intellectual property rights ("Patent", "copy right law", etc. ), and respect third party's intellectual property rights. We will not infringe any of these rights or make illegal copies of computer software.