Group Code of Conduct

All members of the FUNAI Group (hereinafter "We") pledge to make a sincere effort to observe the following code of conduct. Senior management recognizes that it is their role to embody this code of conduct, and that they must take the initiative and set an example for others in the company to follow. In the event their conduct is in opposition to this code, it will be their responsibility to correct themselves publicly and ensure such conduct is never repeated.

  1. We shall develop and provide products and services useful to society with sufficient consideration for the safety and privacy of personal and customer information, and strive to earn the trust and satisfy the needs of consumers and customers while ensuring the healthy development of society.
  2. We shall engage in fair, transparent and free competition and transactions while maintaining a healthy and proper relationship with politicians and political administrations.
  3. We shall ensure management transparency and health through the timely, proactive and fair disclosure of Company information aimed at widening the communication channel with shareholders and greater society.
  4. We shall maintain a safe and comfortable work environment where employee diversity, character and individuality are respected.
  5. We shall respect fundamental human rights and do not engage in discriminatory actions or human rights violations. We do not sanction child labor or forced labor.
  6. We shall voluntarily engage in initiatives aimed at mitigating environmental problems, which we see as common challenge facing all humanity, and recognize as a necessary activity of all corporations.
  7. We shall aggressively promote social contribution activities as a good corporate citizen.
  8. We shall firmly oppose anti-social forces or groups, block all ties with them and reject their undue claims.
  9. We shall observe international law and local ordinances in terms of our international business activities, always respecting local cultures and customs to develop business efficiently.

June 22, 2012