Daigas Group Code of Business Conduct

April 1, 2021 President, Osaka Gas Co., Ltd.

The Daigas Group’s corporate social responsibility is to create new value through fair competition and thereby contribute to society. In fulfilling its corporate social responsibility, compliance is of utmost importance for the Daigas Group.
The Daigas Group Code of Business Conduct (“the Code”) sets the standards of conduct that all of us who work in the Daigas Group including directors, officers, and employees must follow as the Group strives to ensure its compliance with laws and regulations in its business operations.
As we operate business in accordance with the Code, which also forms the basis of the Group’s other internal rules, we should always adhere to the spirit and intent of the Code even in face of any circumstances that fall outside its expected situations, which we might encounter in the rapidly changing business environment.
By delivering on our responsibility in accordance with this Code as well as the Daigas Group Charter of Business Conduct, we aim to be a corporate group that continues to be recognized for its excellence in business operations and needed by customers and society. In the meantime, we strive to keep the Daigas Group evolving as a corporate group for which we always take pride in working.

1. Respecting human rights

We recognize that our conduct in every aspect must be based on our maximum respect for human rights

We maintain our proper knowledge about human rights and treat our customers, business partners, supply chains, employees, and people in the community, in all countries and regions, in a fair and equal manner, and never discriminate them for any reason.

2. Providing safe and secure workplace

We promote workforce diversity, support our employees in performing to their best abilities, act with due respect and consideration to their positions, and provide a healthy workplace which tolerates no harassment and allows them to work comfortably regardless of the form of employment.

Those in higher positions need to be fully aware of their authority and responsibility in their duties and never abuse their authority in performing their duties.

We ensure employees’ safety and promote their health as the most important principle of the workplace and strive to prevent work-related accidents.

We respect our employees’ individual uniqueness and support them for achieving their higher career objectives and improving professional skills.

3. Complying with laws and regulations

We maintain our proper knowledge of and comply with laws and regulations relevant to our business activities.

We conduct business activities based not only on laws and regulations, but also on sound ethical standards.

We set out and follow internal rules and manuals for operating business in compliance with laws and regulations as well as by using common sense.

4. Avoiding use of professional positions and company property for personal reasons

We do not use our positions at work for personal gains.

We do not use the company’s property, whether tangible or intangible, for personal purposes.

5. Complying with laws in each country and region, and respecting international standards including those on human rights

In conducting business activities globally, we comply with the laws and regulations of each country and region where we operate, respect international standards including those on human rights, and give due consideration to culture, customers, and the interests of our stakeholders.

We conduct our business activities in a proper manner in light of the principles of the United Nations Global Compact on human rights, labor, environment, and anti-corruption.

6. Contributing to the environmental conservation

The environment is the basis of all lives on earth. We give proper consideration to the environment in every aspect of our business activities in each country and region.

We strive to conserve and reuse resources and energy in order to contribute to the environmental conservation.

We develop and provide technologies and systems that contribute to the climate change mitigation, and products and services that contribute to the reduction of environmental impact.

7. Complying with anti-monopoly laws and regulations, and conducting fair transactions

We conduct business activities in compliance with anti-monopoly laws and relevant regulations and do not engage in anti-competitive, restrictive, and unfair trade practices.

We maintain equal terms with our counterparties without unduly taking advantage of our favorable positions in business transactions.

We pursue fair trading practices by complying with laws and regulations related to anti-monopoly laws.

We conduct business transactions in compliance with relevant laws and regulations, making fair judgment based on economic rationality by comprehensively taking into account the quality and prices of products and services as the basis as well as other necessary elements.

8. Providing products and services

We provide products and services at reasonable prices, which are designed to meet the needs of society even in the future, in order to contribute to the enhancement of customers’ comfortable lifestyles and the development of their businesses as our corporate mission.

Each of us performs our duties by adhering to basic rules to achieve a high level of professionalism.

9. Ensuring safety of products and services

We ensure safety as a matter of the highest priority in every aspect of products and services including their development, sales, contracted construction work, and utilization.

We strive to achieve a level of safety from customers’ perspectives as well as to fulfill legally required safety standards.

When accidents occur with products, we will immediately investigate their causes and prevent their recurrence. Simultaneously, we will examine the extent of damage and risk and take necessary actions including recovery of products and notifying users of their exposure to risks and dangers.

We prepare against disaster with reasonable and sufficient response measures in order to prevent the extent of damage from increasing, minimize such risks, and ensure the continuity of our safe and stable supply of products and services to customers.

10. Interacting with customers appropriately

We observe our principles in our interaction with customers including pleasant greetings, polite wording, proper outfit, sincere attitude, and keeping promises.

We provide customers with easy-to-understand explanations from their standpoint and accurate information on our products and services so that they can make informed decisions in commercial transactions.

We respond promptly in the event of an accident or to customers’ complaints and grievances, own up to our errors, and take necessary actions including work improvement and prevention of recurrence.

We do not violate laws or accept unreasonable demands even if customers request them.

11. Engaging with and contributing to society

We actively engage with our stakeholders for the purpose of building a better society and business.

We keep our minds open to broad social issues and maintain our awareness on our bounden duty to make our contribution to society.

12. Building and maintaining sound relationships with business partners

We maintain our association with our business partners within the legally and socially allowable range.

We maintain transparency and soundness of our association with civil officials and public institution staff by fully understanding the objectives set out in the National Public Service Ethics Act, the Unfair Competition Prevention Act, Anti-Corruption Laws* and other laws and regulations relevant to the prevention of corruption.

We provide entertainment and other activities within the scope of social common sense and in accordance with our internal regulations and business practice manuals.

In placing orders or engaging in purchasing activities, we refuse to receive entertainment and gifts from business partners.
*Anti-Corruption Laws
Foreign Corrupt Practices Act (USA) and the Bribery Act (UK) etc.

13. Engaging business partners in following Daigas Group Code of Business Conduct

We promote the understanding of our supply chain including our suppliers on the principles of our Code depending on the nature of their transactions in order to gain their cooperation in following our Code.

14. Managing proper use of information and systems

We value information as an important corporate asset and handle it properly while preventing its leakage and loss.

We gather, manage, and use personal information responsibly.

We do not use information about the Daigas Group that is not publicly available (inside information) for buying or selling the Daigas Group companies’ securities (prohibition of insider trading).

We appropriately use e-mail and other internet-based communication systems in compliance with our internal rules. We do not use company’s information systems for personal purposes.

15. Disclosing information and engaging with stakeholders

We disclose information in a timely and an appropriate manner on the Daigas Group’s corporate management and on facts that affect the corporate management, and information that should be disclosed in response to social requests.

We engage with our stakeholders including customers, shareholders, and communities to promote their better understanding on the Daigas Group in light of the difference and similarities between them and the Group.

16. Properly handling intellectual property

We value intellectual properties as important corporate assets and properly manage our own intellectual properties while preventing infringement on others’ intellectual property rights.

17. Avoiding association with anti-social groups and individuals

Under no circumstance do we tolerate dealings with or giving favors to anti-social groups or individuals, including transactions without transfer of money or assets such as unreasonable discount.

18. Making tax payment and performing accounting practices properly

Acknowledging the importance of properly paying taxes for a corporate entity as a member of society, we maintain adequate knowledge on taxes and properly pay taxes.

We conduct appropriate accounting procedures in accordance with accounting regulations and operational manuals.

*“Our Declaration” - A Summary of the “Daigas Group Code of Conduct”

To promote better understanding of the Daigas Group Code of Conduct, we prepared “Our Declaration” consisting of 10 items, which is an extracted essence of the Code of Conduct. A pocket-size card bearing “Our Declaration” has been distributed to all Group employees. The declaration is also posted on the Group's intranet system for dissemination to all employees.

• Our Declaration

Widespread Thorough Understanding of the “Daigas Group Code of Business Conduct”

A paper version of the Code of Conduct and a pocket-size card bearing the Code of Conduct has been distributed to all employees, and posted on the intranet for dissemination to all employees.
We have also posted an Explanation of the Code of Conduct on our intranet and incorporated the Code of Conduct into training and similar activities to deepen employees’ understanding.