Ushio Inc. has established the 10 Action Guidelines as a Member of Society as a set of action guideline for all employees to act in compliance with laws, regulations, the Articles of Incorporation, and the Management Philosophy. We have also established the Compliance Committee to ensure that the guidelines are thoroughly implemented, and are striving to foster compliance awareness through various education and training for all employees. The Internal Audit Department, in cooperation with the Compliance Committee and related departments, audits the status of compliance, including the action guidelines and the following items, and reports to the Board of Directors and the Audit & Supervisory Committee as appropriate. In addition, the Action Guidelines are applied to and utilized by each Group company, and the Internal Audit Department conducts audits of Group companies. The effectiveness of the Action Guidelines, related regulations, and specific compliance measures is evaluated, verified, and improved at least once a year by the Compliance Committee.

All reports received by the Ushio Helpline are reported to the Chair of the Compliance Committee. In the event that an officer or employee of Ushio becomes aware of a compliance violation or a suspected violation, the Compliance Committee immediately investigates and responds, and together with the relevant departments, formulates corrective measures and measures to prevent recurrence and ensure to implement recurrence prevention.

Compliance with Laws and Regulations Related to the Security of Exports

Ushio Group has adopted a basic policy of not engaging in any export or export-related transactions that impair the maintenance of peace and security worldwide, and is implementing various measures for security export control.

We have established an internal rules and guidance (CP: Compliance Program) for compliance with export-related laws and regulations in order to secure our system for promoting security trade control. Based on the CP, our export controls are conducted to determine cargos and/or technologies are whether appearing on the List controlled items or not. At the same time, the entire content of transactions is reviewed by confirming end users and application, and decisions on whether or not to export a cargo or technology are to be made.
In addition, we are building a self-management system through measures such as responding to legal revisions, employee education, and internal audits.

As a result of establishment of these export control systems, we have obtained a Bulk Export License from METI that can be granted only to exporters with strict control.

Ushio Helpline

The Ushio Helpline has been in operation in the Ushio Group since October 2006. When any Group employee in Japan is subject to or knows about improper behavior, such as workplace violations of laws and regulations, internal rules (including bullying, harassment, etc.), ethics or other standards for behavior, he or she can use this helpline for direct communication with individuals outside the Group to consult or report on this improper behavior. The helpline allows for quick discovery and correction of improper behavior together with measures to prevent recurrence. It provides access to consultations while protecting individuals who use the helpline from any negative consequences.

All whistle-blowing statements received via an external channel are immediately reported to the chair of the Compliance Committee, who is a managing director appointed by the president. Under the direction of the chair of the Compliance Committee, Ushio aims to quickly resolve issues by conducting audits, responding to incidents, and putting in place measures to prevent a reoccurrence.

Information Security

The Ushio Group believes that ensuring to protect information assets, such as personal information of customers often handled in the course of its business activities and important corporate information entrusted to us by customers, from threats including leakage and falsification, is an important issue.Furthermore, based on the recognition that information is an asset that creates value and a source of increasing corporate value, we are promoting increased information security awareness among employees and the development of a risk management system, etc.

In these practices, it is necessary to take three-pronged actions including "determining the rules," "creating a system to comply with the rules," and "raising awareness." We are working toward operations in accordance with the Information Security Management Regulations and to homogenize the rules within the Group, including overseas.
In particular, we believe that it is important to review security rules as appropriate to adapt to changes in the business environment.

As a specific initiative, we have established a Group Policy in 2023 to strengthen information security management and risk management for all Group companies, and are working to increase information security literacy by promoting education and awareness-raising activities according to the security level of each Group company.
At Group companies in Japan, by analyzing computer operation logs using AI, we are able to detect internal information leaks at an early stage and enhance deterrence.
Also, as a countermeasure against targeted e-mails, we have introduced a Security Operation Center (SOC) to monitor and analyze external threats, and to protect information assets from leakage or loss by detecting and preventing external attacks at an early stage.
However, systemic measures alone are not enough. It is important to continuously improve the security awareness of employees, and for this reason, we conduct in-house training through e-learning every year. We are also working to increase information literacy by conducting drills on targeted attack emails.

These activities are positioned to protect the interests of our customers and stakeholders, and we will promote them globally so that each and every employee maintains a high level of awareness.

Protecting Intellectual Property Rights

Ushio takes the following measures to protect its own intellectual property rights and ensure that it respects the rights of other companies. 1. We will observe laws and regulations pertaining to industrial property rights, copyrights and other intellectual property rights. 2. We will make efforts to manage risk in order to prevent other companies from infringing upon our intellectual property rights and to ensure that we do not infringe upon the rights of other parties. 3. We will strive to submit applications and obtain rights in a timely manner in line with business development, and thus to contribute to vigorous corporate activities. 4. We will consider the overseas countries and regions in which we submit applications as well as the content of overseas applications in an effort to enhance our overseas competitive strengths 5. We will ensure that all employees understand management rules pertaining to employee inventions, and will observe these rules.

Initiatives for Prevent Corruption

Ushio has established the Anti-Corruption Policy as a guideline for thoroughly preventing all forms of corruption throughout the Group and fulfilling its social responsibilities.

Ushio's 10 Action Guidelines as a Member of Society for business activities commit us to conducting fair and equitable business transactions, and we have always taken vigorous action to prevent corruption. In these Guidelines, Chapters 6 and 7 are designed to prevent corruption. They have the provisions shown below.

6. We shall comply with laws and regulations and carry out fair business activities in accordance with socially accepted practices.
"When offering any gift or entertainment, we will comply with laws and regulations and always limit it to the nature, frequency and value appropriate in light of social norms. When receiving an offer of any customary or courtesy gift, such as seasonal gifts, in relation to business, we will politely refuse it. Also, in response to an offer of any meal or entertainment, we will refuse it as a general rule.
We will deal with governmental offices in compliance with applicable laws and regulations and in fair and open manners. We as a business entity may request the revision or abolition of industrial and economic systems or policies from politicians and government. However, we will always do so in fair and open manners. When offering political donations, we will comply with applicable laws and regulations and expect no specific reward or favors to be provided."
7. We shall fulfill our duties to the best of our abilities in conformity with internal regulations and standards.
"We will always draw a clear line between corporate and private matters and gain no personal interest in association with business positions or duties."

In 2010, Ushio became a signatory of the United Nations Global Compact's Ten Principles, which include provisions for preventing corruption, and we support the prevention of corruption and bribery in business activities.

Specific Activities

In our operations, we are concerned about the risk of bribery to promote sales of laboratory instruments, light source products and medical equipment to universities and government agencies. In sales of medical equipment in particular, we stress the importance of maintaining proper relationships with our customers, namely medical practitioners. Ushio regularly trains its sales staff on transparency guidelines with the aim of preventing corruption.

Newly appointed procurement managers rigorously further greater understanding of the Company's procurement practices and work to prevent inappropriate relationships with business partners. In operations related to the sale of our wide range of products and the procurement of materials, there are concerns that efforts to prevent corruption and bribery will become increasingly complex as the Company's scope of operations expands overseas, owing to the possibility that overseas laws and regulations pertaining to the prevention of corruption (especially FCPA in the US and UKBA in the UK) will apply to other regions.

We provide individualized anti-corruption trainings related to each employees’ duty operations. In addition, we provide managers with trainings specific to the above concerns in light of the global trend toward stricter enforcement of anti-corruption laws, and all employees are required to read through "the 10 Action Guidelines as a Member of Society" during our Compliance Month. Through these efforts, we are working to ensure that all employees throughout the company are fully aware of the importance of anti-corruption.

The Ushio Hotline is the direct line of communication for employees to file reports, including reports related to the abovementioned items of concern, which may be reported anonymously.In fiscal 2022, we held a training session for all employees with the aim of disseminating and increasing the awareness and penetration of the Anti-Corruption Policy, with 631 employees participating. In order to strengthen and instill compliance, we will continue to provide employees with various education, training, and awareness-raising activities.

In the event of illegal actions being confirmed, an investigation conducted by the responsible executive officer acting as Chair of the Compliance Committee reporting directly to the president, or other appropriate action is carried out and reported to the Board of Directors as necessary.
Ushio does not have fines or penalties specifically for corrupt practices, but in the event of a serious situation being detected, it will implement appropriate disciplinary action in accordance with Ushio internal regulations.