Kuraray America, Inc.

Our Commitment We will constantly develop and provide safe, high-quality products and services. 1. Safety and Quality of Products and Services We contribute to Society by supplying safe, reliable and high-quality products and services. We will maintain a sound relationship with Society through good communication. 2. Disclosure of Corporate Information We disclose corporate information, such as business operation and financial information, in an accurate and timely manner, and in accordance with relevant regulations. We will be open to societal opinions and reflect them in our operations. 3. Anti-Bribery/Rules for Donations We must never offer, make or accept bribes of any kind. We do not offer entertainment, gifts, or other benefits to government officials, whether at home or abroad. When making donations or gifts, we comply with laws, regulations, and corporate rules. 4. No Relationship with Anti-Social Group We take a resolute stance against, and will not associate with, anti-social groups or organizations. 5. Contributions to Society Consistent with our status as a good corporate citizen, we will participate in volunteer activities and social action programs. We will strive to preserve and improve the global environment, and to secure safety and health in all our workplaces. 6. Environmental Preservation We contribute to sustainable development and take seriously our responsibility to preserve the environment for the benefit of future generations, through our business operations, which coexist with the global environment and local communities. 7. Safety and Disaster Prevention We take necessary measures to prevent accidents and disasters, such as explosions, fires, or leakages of hazardous materials. If an accident should occur, we contain it and attempt to avoid any contamination, and disclose pertinent information in a timely and accurate manner. 8. Safe and Comfortable Workplace We comply with regulations concerning employment safety at the workplace and strive to ensure a safe and comfortable working environment. We will value all members of the Kuraray community and respect their rights. 9. Respect for Human Rights We respect the human rights of all persons with whom we contact in doing our business and treat them with dignity and respect. 10. Enhancement of Diversity, Equal Opportunity We value diversity in our workplace. We do not discriminate against any person on the basis of personal characteristics, such as race, gender, national origin, and we evaluate individuals fairly. We will always conduct businesses in a free, fair and transparent manner. 11. Compliance with Antitrust/Competition Laws We comply with antitrust/competition laws and we conduct fair transactions with our suppliers and customers, who we view as equal partners. 12. Prevention of Unfair Competition We neither illegally obtain nor improperly use trade secrets belonging to other companies. We also do not conduct any activities that may derogate the business reputation of other companies. In addition, we do not make inappropriate displays of our products, which could lead users to misunderstand the quality and properties of our products. 13. Compliance with Laws Related to Exports and Imports We comply with laws and international treaties controlling the export and import of goods and technologies. 14. Prohibition on Entertainment and Gifts in an Excessive Manner We do not exceed the boundaries of socially acceptable practices when giving or receiving entertainment or gifts to or from business partners. 15. Prohibition on Conflicts of Interest We will not take advantage of one’s position in the Company or exploit information obtained when performing duties in the Company to promote personal interests. 16. Prohibition against Insider-Trading We do not conduct any act that violates or may be suspected of violating laws and regulations concerning insider trading. We will honor all intellectual property and secure data and information in a proper manner. 17. Protecting Trade Secrets Business information, such as trade secrets, know-how and customer information, is an important asset of the Company. We properly use and protect our business information, and the property of other entities, including confidential information received from business partners and others. 18. Protecting Intellectual Property We acknowledge that intellectual properties are important assets of the Company and we properly protect them. We respect intellectual property rights of third parties and avoid infringement and misuse of such rights. Compliance Handbook “Kuraray Group Compliance Handbook” gives you a clear explanation of the “Kuraray Group Code of Conduct” flowing from “Our Commitment” which each and every member of Kuraray Group should share.