H.U. Group Code of Conduct

When becoming aware of any circumstance that may possibly infringe upon this Code of Conduct, Company Personnel must immediately report the matter to their supervisors or through the H.U. Group whistleblowing hotline.
Each H.U. Group company should resolve the problem, identify causes and prevent recurrence as a company after receiving a report concerning such matter and, if necessary as required by applicable laws or regulations, disclose information and provide explanations to the public and the applicable government agencies in a timely and accurate way.

The safety and quality of our products and services is of utmost concern to the H.U. Group. In order to ensure that the lives, health and assets of customers and patients are not harmed, every H.U. Group company will pay close attention to the functions, safety and other characteristics of its products and services in each phase of handling from research and development to the time after market launch, to ensure compliance with all applicable laws, regulations, guidelines, and voluntary industry standards, and in addition, if no relevant standards exist, shall formulate voluntary standards in line with the operating conditions of such company and this Code of Conduct and comply with such standards.

Every H.U. Group company shall, when conducting research and development activities, ensure scientific integrity, rigor, and reliability while complying with all laws and regulations, guidelines, voluntary industrial standards, and internal rules regarding the protection of human rights and privacy of research participants, bioethics, animal protection and other relevant matters.

In the event an accident or unintended incident arises with regard to a product or service provided by a H.U. Group company, such company will convey accurate information to customers and business partners, and if required under applicable laws and regulations, to the applicable government agencies, without delay and make a prompt and appropriate response to minimize the damage, and in addition, will also thoroughly identify the cause and adopt procedures to prevent its recurrence.

The H.U. Group believes that competition in the market should be based on the overall competitiveness of each product and service, and hence, takes action from the perspective of customers and patients at all times, including precisely identifying their needs and enhancing post-sales services.
It is H.U. Group’s policy to comply with the antimonopoly, antitrust and competition laws of countries and regions in which it conducts business activities, and to not take any actions that limit fair and free competition in the market or gives rise to the appearance of such actions.

Every H.U. Group company shall, when issuing advertisements and conducting promotional activities on products and services, be aware of its social responsibilities as business operators in medical-related fields, and comply with all applicable laws and regulations, guidelines, voluntary standards prescribed by the industry, and internal rules governing such activities.

The H.U. Group encourages research and development activities, and protects the results of such activities through intellectual property rights. Intellectual property rights include patents, designs, trademarks and other industrial property rights, and copyrights, as well as know-how and trade secrets relating to business activities and technologies. Company Personnel shall take all appropriate actions to protect and maintain in confidence all information regarding research and development activities and inventions so that appropriate intellectual property rights, such as patents, may be applied for and maintained.
We will also take adequate care so as not to unfairly infringe on intellectual property rights of others.

H.U. recognizes the importance of protecting personal information, especially healthcare information obtained through clinical tests, clinical trials or studies. It is H.U.’s policy to protect such personal information in accordance with applicable laws and regulations, and internal rules in all areas where we conduct business activities, including the personal information of persons such as customers, patients, business partners, and Company Personnel in an appropriate manner.

H.U. will respect ideological and cultural diversity and aim for the realization of a creative and free society.
H.U. will respect the cultures and favorable customs of countries and regions in which we conduct business, and aim for co-existence and co-prosperity with local communities.

In order to protect the global environment, the H.U. Group will provide society with products and services that are not harmful to people and the environment, while conducting its corporate activities in a manner designed to place the minimum burden on the environment.

When offering a donation to an organization or corporation, the H.U. Group will adequately consider the necessity and validity of such donation as part of its CSR activities.

The H.U. Group will reject any relationship whatsoever with any organization or individual that might possibly impede social order or sound corporate activities, and will maintain a firm attitude against such organizations and individuals. Furthermore, if any such organizations or individuals try to contact any H.U. Group company, or make any demands for money, or otherwise, the H.U. Group company will reject such demands, terminate communications with such organization or individual and, if deemed appropriate or required by applicable law or regulation, will report such activities to the appropriate governmental agencies.

The H.U. Group recognizes that proper accounting procedures and highly reliable financial reporting are critical to win trust from society and all its stakeholders, and will establish and operate an internal control system that ensures such appropriateness and reliability. In addition, H.U. will make entries and statements in slips, books and other accounting documents accurately and appropriately in compliance with the related laws and regulations, applicable accounting standards and internal rules and will under no circumstances engage in any misrepresentation, deception, accounting fraud or other misconduct.

In compliance with applicable laws and regulations, the H.U. Group will disclose information required by shareholders, investors, business partners, local communities and other parties at appropriate times and using appropriate methods in an accurate and fair manner, and will also prohibit insider trading using undisclosed information and shall deal strictly with any violator.

Every H.U. Group company will maintain a healthy, safe and hygienic working environment, and actively work to make improvements to such environment.
We will not allow unfair discrimination or harassment (such as sexual harassment or power harassment), slander, bullying or any other behavior causing a nuisance to other Company Personnel, or any other action that prevents us from maintaining a good working environment.

Company Personnel should not pursue personal benefits, for themselves, their family members or associates, by using business opportunities, business information, human relationships, customer lists, and customers’ credit information, obtained through the business activities of the company.

Company Personnel should appropriately protect funds, goods and other assets of each H.U. Group company, and should not use such assets for purposes other than business activities of such company and purposes approved by the company.
Company Personnel should use computers, smartphones, and other equipment, apparatus and consumables provided by the company only for purposes of business activities of the company in accordance with the rules of the company, and should not use such items for personal purposes. Upon any termination of employment or association with the H.U. Group company, Company Personnel should promptly return all such equipment and other items to the company. Upon any transfer to another H.U. Group company, Company Personnel should return any such equipment that will no longer be required.

Company Personnel should, during their association with the H.U. Group and following the termination of such association, strictly maintain the confidentiality of company information regarding business activities and/or technologies including trade secrets relating to products and services, research and development activities, and business activities of the company, and should not disclose such information to third parties, expect as required in the performance of their duties, and should not use any of such information for any purpose other than permitted company activities. In addition, Company Personnel should disclose such information only to such other Company Personnel who need to know such information in connection with the permitted activities of the company.
Company Personnel should not obtain confidential information of third parties using illegal or unfair methods. It is also prohibited to demand Company Personnel to disclose third party information that they obtained prior to joining the H.U. Group company and for which they hold a duty of confidentiality.

H.U. Group will, when selecting a supplier, select the most appropriate one after comparing the various conditions and opportunities associated with the business transactions in a fair and proper manner. In selecting a supplier and executing a transaction, H.U. Group will not abuse its advantageous position nor demand special benefits or favors.
With regard to any offer of entertainment or gift (unless the gift is of nominal value pursuant to the internal rules and will not cause a conflict of interest or an apparent conflict of interest) from a supplier, we will timely decline or return the offer.

It is H.U. Group’s policy not to offer money or gifts to, or entertain, public officials and/or foreign public officials (including assembly members, candidates thereof, and any other persons who are treated under applicable law as government officials or employees) of any countries, with the intention of acquiring or maintaining business transactions, or receiving undisclosed information, or for the purpose of having an effect on the execution of duties by such public officials.
We will also make efforts so that the aforementioned acts will not be executed through agents, consultants and other parties that support our business activities.

Every Company Personnel may, if judging that any of the various actions encountered during corporate activities is or might be in violation of laws and regulations, internal rules and/or this Code of Conduct, report the matter through the whistleblowing hotline established by H.U. Group Holdings, Inc. or each H.U. Group company.

Every H.U. Group company will not treat whistleblowers disadvantageously for the reporting made based on their honest concerns, except in cases where the whistleblower himself/herself has been involved in an act of violation, and will not tolerate retaliation against anyone who in good faith seeks advice, raises a concern or reports misconduct.

Violations of this Code of Conduct will lead to appropriate disciplinary action in accordance with the policies of each H.U. Group company, up to and including termination of employment.