Sapporo Group Code of Conduct

We place the highest priority on customer satisfaction and trust, providing safe, high-quality products and services.

• We focus on quality and provide safe, reliable products and services.
• We listen attentively to our customers and create value that goes beyond their expectations.
• We provide clear and accurate information about our products and services.
• If there is a problem with a product, we address it promptly and in good faith.

We work to address social issues, including those related to human rights and the environment, and pursue the creation of a sustainable society and the enhancement of corporate value over the medium to long term.

• We act in accordance with international norms, including the International Covenants on Human Rights, and uphold the human rights of all people.
• We do not tolerate discrimination, harassment, child labor, or forced labor, and take steps to prevent human rights violations.
• We continue to carry out human rights due diligence to identify, prevent, and mitigate negative impacts on human rights across the value chain.
• We put processes in place to provide remedy if human rights violations occur and take necessary follow-up action.
• We position environmental action as a key management priority, including efforts to address climate change and help build a carbon-neutral, circular society.
• We promote responsible drinking by helping to prevent harmful drinking, including drinking by those under the legal age and drunk driving, and raising awareness of moderate drinking habits.
• We actively engage in a wide range of initiatives that contribute to society and work to build positive relationships with local communities.
• We act in accordance with international norms, understand the laws and cultures of the countries where we operate, and conduct business accordingly.

We comply with all applicable laws and regulations, observe social norms, and conduct our business with fairness and transparency.

• We comply with the Antimonopoly Act and other competition laws, and engage in free, fair, and transparent competition.
• We prohibit bribery and corruption in any form.
• We maintain fair and impartial procurement processes and ensure transparency in those processes.
• We prevent money laundering and have no dealings with organized crime groups or other anti-social forces.
• We maintain accounting records and file tax returns accurately.

We create a safe and rewarding workplace where people with diverse backgrounds and perspectives can thrive.

• We promote diversity, equity, and inclusion (DE&I).
• We ensure occupational health and safety and maintain a healthy and secure work environment.
• We support the professional growth of each employee and provide opportunities for them to make the most of their abilities.
• We comply with labor laws and regulations, and ensure fair working conditions.

We seek to build relationships of trust with all stakeholders and achieve sustainable growth through constructive dialogue and transparent disclosure.

• We provide shareholders and investors with timely, accurate, fair, clear, and useful information, fulfilling our accountability to stakeholders.
• To achieve sustainable growth and enhance corporate value, we build an effective governance framework, continue to review and improve its effectiveness, and ensure transparent management.
• We take rigorous measures to prevent insider trading.
• We listen attentively to a wide range of stakeholders, including customers, business partners, employees, and local communities.
• We avoid conflicts of interest by following established procedures.

We exercise due care in managing and protecting information entrusted to us by customers and business partners, as well as the company’s confidential information.

• We comply with the Act on the Protection of Personal Information and other relevant laws and regulations.
• We maintain an information security framework and protect information assets from cyberattacks and other threats.
• We prevent the unauthorized disclosure of confidential information and trade secrets, and manage them securely.
• We protect and use intellectual property rights effectively, and do not infringe the intellectual property rights of others.
• We do not allow company assets to be used for personal purposes.
• When using AI, we follow internal rules and use it responsibly.

We manage significant risks that may affect our business activities and take swift, effective action in the event of a crisis.

• We maintain a risk management framework to identify, assess, and manage significant risks, and continue to review whether the framework is working effectively.
• We develop business continuity plans (BCPs) to prepare for emergencies, including natural disasters, pandemics, and accidents.
• When a crisis occurs, we put human life and safety first, work to minimize damage, determine the cause, and take steps to prevent recurrence.
• We provide stakeholders with timely and accurate information.

Top management recognizes its responsibility to put the spirit of this Code into practice and takes the lead by setting an example.

• Top management establishes an effective governance framework and works to embed corporate ethics across the group.
• If a situation arises that goes against this Code, top management takes the initiative in resolving the issue, identifying the cause, and taking measures to prevent recurrence.
• Top management fulfills its accountability to society, clearly defines lines of authority and responsibility, and takes firm disciplinary action, including against members of top management where necessary.
• Top management asks the group’s business partners, including suppliers and contractors, to understand the principles of this Code, encourages them to act in line with its spirit, and works with them to foster corporate ethics and raise awareness.
• Top management ensures the effectiveness of these efforts through regular monitoring and evaluation of business partners.