ELM Technology Corporation
Code of Conduct for CSR

[ Preface ]

ELM Technology Corporation pays attention to the international common code of conduct, follows our government/community laws, rules and regulations, and also respects the code of conduct by industry and customers.
ELM Technology Corporation defines the following code of conduct for CSR in five categories. We announce the code in public and also ask our suppliers understanding and following the code. We cooperate with the suppliers to share information to obey the code of conduct and we constantly review it to follow changed and required social demands.

[ Code of conduct ]

1.Labor and human rights

1) No Forced labor
We respect the free will of employees and avoid forced labor.
2) No Children employment
We do not employ children and limit job assignments for young employees following a labor law.
3) Working hours
We follow labor regulations on the limitation of weekly working hours and necessary days off a week.
4) Wages
We pay wages more than minimum wages by regulations and full of amount without unreasonable reduction.
5) No inhumane act
We respect the employee's human rights. We forbid harassment and abuse.
6) No discrimination
We do not discriminate on race, the color of complexion, nationality, age, gender, sexual orientation, disability, pregnancy, religion, political view, union membership, and marital status.
7) Freedom of association
We guarantee freedom of association, union membership, and right of protest for employees following regulations.

2. Labor safety

1) Ensuring safety in the workplace
To ensure the safety of employees, we assess the work environment and work conditions on hazards and potential hazards. Where applicable, appropriate technical, and managerial measures are to be taken to prevent or reduce the use of such substances. Protective equipment is to be provided to employees as necessary.
2) Accident prevention and preparation for emergency
We evaluate the risk of accidents and disasters and take action for emergency preparation. We check the safety of the working environment and the alarm system for disaster.
3) Prevention of employment-related accident and illness
We identify employment-related accidents and illness, and work to prevent them. We implement a medical examination program for employees following regulation.
4) Management of physical load and illness by employment
We manage employees' heavily loading jobs in physical and potential hazardous on health including mental side to prevent employment-related accidents and illnesses.
5) Safety of machines and instruments
We take actions evaluating the safety of machines and instruments to prevent labor accidents.

3. Environmental protection

1) Environmental compliance
We comply with environmental laws and ordinances.
2) Saving resources and energy
We take action saving resources and energy.
3) Drainage management
We do not drain hazardous water in all of our business flow.
4) Management of air pollution
We make efforts to exhaust the minimum volume of toxic gas, greenhouse gas, and ozone layer depletion gas.
5) Waste control
We process waste correctly and reduce its volume in our business.
6) Environmental hazardous chemicals control
We reduce the use of the chemicals in the regulations, replace with the safer chemicals, and make an effort to stop emissions.
7) Management of products containing chemicals
We identify hazardous chemicals in our products and keep managing to exclude the chemicals by the monitoring system under laws and regulations such as "RoHS" and the JAMP guidelines in comparison to the environmental standards of the industry and customers. Also, further upstream suppliers in the supply chain are informed of the contents and requested to comply with them
8) Consideration of biological diversity
We pay attention to our business activity influences on biological diversity and work to minimize it.

4. Ethics

1) No business with criminal organizations
We never have business with anti-social forces. We never do corruption, bribery, and coercion.
2) Fair competition
We manage to do a fair competition in business.
3) Disclosure of company information
We disclose our company and business information correctly.
4) Disclosure of products information
We disclose our product information correctly to our customers.
5) Dishonesty prevention and internal reporting
We detect and prevent dishonesty and transgressions. We protect informants to be able to report a dishonest act retaliation.
6) Protection of intellectual property
We respect intellectual property rights and manage to protect them.
7) Protection of personal information
We protect the personal information of whom relating to our business, customers, suppliers, consumers, and employees.

5. Others

1) Business continuity program(BCP)
We understand BCP is important for customers and suppliers. We prepare BCP for huge disasters and serious accidents at all times.
2) Responsible minerals sourcing policy
If our product contains the 3TG minerals (tin, tantalum, tungsten, gold) and cobalt, we use lower risk materials. As for minerals produced in conflict-affected and high-risk areas including the Democratic Republic of Congo (DRC) and its neighboring countries, we promote the responsible mineral procurement, no giving direct or indirect profit for the criminal organizations involved in all risks and abuses, such as child labor and other human rights abuses, bribery, and money laundering.
We use RMI's survey form to investigate that the minerals are sourced from suppliers that are not involved in risk or fraud, and we take corrective measures if there is a risk of involvement.

July 20, 2020
President CEO
Ikuo Kurihara