MEG Code of Conduct

1. Provide safe and high-quality products, construction work, services, etc.

   As a company involved in the construction of social infrastructure, we are aware of our social mission to ensure public safety and provide high-quality construction products, and we respond to the needs of society and our customers by strengthening and enhancing safety measures, improving our technical capabilities, and developing and proposing new technologies to gain customer satisfaction and trust.

   • 1-1　We shall strive to improve customer satisfaction and earn trust

     ○　We shall correctly grasp our customers’ needs and requests, and respond to them sincerely, promptly, and accurately by making the most of the Group’s technology and experience, to provide safe and high-quality products, construction work, services, etc. that will satisfy our customers.
     　　Furthermore, we shall provide our customers with appropriate information on design, planning, estimates, etc. for products, construction work, and services, and strive to comply with construction-related laws and regulations, technical guidelines and standards, contracts, etc.

   • 1-2　We shall strive to maintain and improve technical standards

     ○　We shall strive for the sustainable development of technology by appropriately passing on our technologies, skills, and experience, based on “advanced manufacturing” in accordance with the ethics of engineers.
     　　We shall also develop and propose new technologies and work to utilize the latest and best technologies in design, manufacturing, on-site construction, and other processes to satisfy our customers and meet the demands of society.

   • 1-3　We shall strive to enact and establish a quality and safety assurance system

     ○　We shall give constant consideration to safety in the manufacture and transportation of our products, and construction works, and we shall take all possible measures to ensure safe facilities, safe work methods, and safety training in order to complete construction without causing an accident or disaster.

     ○　We shall endeavor to enact and establish a quality and safety assurance system, including a management system for quality and safety, and if any defect occurs or complaints are made regarding our products, construction work, services, etc., we shall promptly report such information to our supervisors in accordance with the prescribed standards and procedures, inform our customers of the facts, and take prompt action to address the situation.

2. Compliance with relevant laws and regulations, fair competition

   We shall observe the Antimonopoly Act, the Construction Business Act, and other relevant laws and regulations, as well as social norms, and engage in fair, transparent, and free competition and appropriate business transactions.
   Furthermore, we shall maintain wholesome and normal relations with politicians and governments.

   • 2-1　We shall comply with the Antimonopoly Act and other laws and regulations

     ○　We shall comply with the Antimonopoly Act and other laws and regulations, and encourage fair trade, based on the principle of free competition, with all business partners.

   • 2-1-1　We shall not engage in bid rigging, cartels, or other unfair practices among competitors

     ○　We shall not enter into any arrangements with companies in the same industry with respect to prices, production quantities, business partners, etc. of products, construction work, services, etc., or with other bidders with respect to successful bidders or bidding prices, or engage in any other acts that impede free and fair competition.
     　　Furthermore, we shall not participate in any meetings or exchange information that may lead to restrictions on free competition, or engage in any acts that may lead to the suspicion that we are involved in such activities.

   • 2-1-2　We shall not engage in unfair competition

     ○　We shall not engage in acts of unfair competition, such as obtaining or using other companies’ trade secrets by improper means or making misleading representations to customers regarding other companies’ products.

   • 2-1-3　We shall appropriately conduct business with business partners

     ○　We shall select business partners such as partner companies and other subcontractors and suppliers based on reasonable and fair comparisons and evaluations, maintain cooperative relationships based on mutual trust that respect each other’s position, and thoroughly ensure that there are no late payments or other violations.

   • 2-2　We shall comply with the Construction Business Act and other laws and regulations

     ○　We shall comply with the Construction Business Act and other applicable laws and regulations, enter into fair construction work contracts, ensure proper execution of construction work through the qualified assignment of engineers, etc., and perform contracts faithfully.

   • 2-3　We shall not make illegal donations or political contributions

     ○　We shall give adequate consideration to the necessity and appropriateness of donations and properly donate in accordance with the relevant laws and regulations. Furthermore, we shall act appropriately in accordance with the Political Funds Control Act, the Public Offices Election Act, and other relevant laws and regulations with regard to political contributions, elections, and political activities.

   • 2-4　We shall not engage in bribery or excessive entertainment or gift-giving

     ○　We shall not bribe domestic or foreign public employees or engage in any acts suspected of being bribery. Furthermore, we shall not provide or accept entertainment or gifts that exceed socially acceptable standards.

3. Ensure information security and protect intellectual property

   We shall strictly manage confidential information, customer information, personal information, etc., giving sufficient consideration to the security of information systems, to prevent leaks to third parties, use for other purposes, and other illegal acts. Furthermore, we shall endeavor to protect intellectual property rights and shall not engage in acts that infringe on or misappropriate the rights of others.

   • 3-1　We shall build and manage information systems properly and we shall not use such systems for any purpose other than the defined business purposes

     ○　We shall properly build and manage our information systems and use them for specific business purposes and not for any other purpose.

   • 3-2　We shall properly protect personal information

     ○　We shall strictly manage personal information to prevent unauthorized access to personal information and any loss, destruction, alteration, or leakage of personal information.

   • 3-3　We shall appropriately protect information on customers, business partners, etc.

     ○　We shall not use information on customers, subcontractors, suppliers, or other business partners obtained in the course of our duties for any purpose other than legitimate purposes, and we shall strictly manage such information so that it is not disclosed or leaked.

   • 3-4　We shall not illegally obtain or use confidential information, etc.

     ○　We shall not illegally access or obtain confidential information on customers, subcontractors, suppliers, other business partners, etc., or competitors, etc.

   • 3-5　We shall respect intellectual property

     ○　We shall strive to maintain and secure our intellectual property rights (patent rights, copyrights, utility model rights, design rights, trademark rights, etc.) and we shall strictly preserve such rights while also respecting the intellectual property rights of others and appropriately obtaining and using such rights without infringing upon them.

4. Appropriate management and timely disclosure of corporate information and assets

   We shall conduct proper accounting procedures in accordance with laws and regulations, accounting standards, etc., appropriately manage corporate information and assets, and disclose information required by society concerning the state of our management and our overall corporate activities in a timely and appropriate manner.

   • 4-1　We shall properly manage and use corporate assets

     ○　We shall properly manage corporate assets (tangible and intangible assets) in accordance with prescribed rules, and we shall not use corporate assets for any purpose other than our operations, including diversion for personal use.

   • 4-2　We shall adopt proper accounting procedures

     ○　We shall comply with all applicable laws, regulations, standards, and company rules and accurately record accounting information, and we shall not adopt improper account procedures or engage in misleading reporting.
     Furthermore, we shall strive to maintain and improve our accounting systems to ensure the prompt and accurate disclosure of accounting information.

   • 4-3　We shall manage confidential information properly

     ○　We shall appropriately classify and manage the Company’s confidential information according to its level of importance. We shall not leak information obtained in the course of our duties to third parties without the Company’s permission, nor shall we use such information for any purpose other than business purposes.
     Furthermore, we shall maintain the same confidentiality obligations after separation.

   • 4-4　We shall not get involved in conflicting interest transactions

     ○　We shall not engage in any activities that conflict or may conflict with the interests of the Company, such as working for or having financial relationships with competitors, business partners, etc.

   • 4-5　We shall disclose legal information in a timely and appropriate manner

     ○　We shall disclose corporate information, such as the status of management and corporate activities to shareholders, investors, etc. in a timely manner, in accordance with applicable laws and regulations, etc. We shall provide correct information.
     We shall always ensure the accuracy of the corporate information we disseminate, and shall disseminate information at appropriate times and in an appropriate manner, taking the need to maintain confidentiality into consideration.

   • 4-6　We shall prevent the occurrence of insider trading

     ○　We shall not use undisclosed information about the Company, its affiliates, or its business partners that we obtain in connection with our duties or transactions to engage in insider trading in securities, such as trading shares.

   • 4-7　We shall prohibit the communication of undisclosed material facts, etc.

     ○　If we learn undisclosed material facts about the Company, its affiliates, or its business partners in connection with our duties or transactions, we shall not communicate such material facts to others or recommend others to buy or sell shares, etc. with the intent of allowing others to profit or avoid losses by having them trade shares, etc

5. Maintenance of a safe and comfortable workplace environment and respect for the individual

   We shall respect the diversity, personalities, and individuality of our employees, ensure a safe and comfortable workplace, and encourage an effective work-life balance.

   • 5-1　We shall comply with labor-related laws and regulations and employment rules, and support career development of employees through fair human resources evaluations and treatment.

     ○　We shall comply with labor-related laws and regulations, employment rules, and various related regulations, and we shall work to improve the job skills of employees through the introduction of a fair human resources system, various training programs, and by encouraging employees to acquire qualifications, etc.

   • 5-2　We shall create a safe and comfortable workplace

     ○　We shall establish a health and safety management system to prevent occupational accidents, strive to conduct workplace risk assessments, and promote the maintenance of physical and mental health and the creation of a comfortable workplace environment.

   • 5-3　We shall respect human rights and eliminate discriminatory treatment

     ○　We shall respect the fundamental human rights of individuals and their diverse values, individuality, and privacy, and prevent (i) discrimination on the basis of nationality, gender, creed, age, or disability, (ii) harassment and bullying, including acts of violence, sexual harassment, and abuse of a superior bargaining position in the workplace, and (iii) acts that disrupt workplace order and work performance.

6. Preservation of the environment

   We shall comply with laws, regulations, and other standards relating to environmental preservation, and work to reduce our burden on the environment, conserve and reuse resources, and reduce waste. In particular, we shall engage in business activities that give due consideration to the recycling and proper disposal of construction by-products.

   • 6-1　We shall promote environmentally friendly business activities

     ○　We shall work to reduce waste generated at our factories and construction sites. In particular, we shall engage in business activities that give due consideration to the recycling and proper disposal of construction by-products.
     Furthermore, we shall aim to reduce the environmental impact of all of our business processes, promote resource and energy conservation, and strive to conserve the global environment and prevent global warming.

   • 6-2　We shall promote the disclosure of climate-related financial information

     ○　We endorse the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD), established by the Financial Stability Board (FSB) to examine how climate-related information should be disclosed and addressed by financial institutions, and we are working to disclose climate-related financial information.

7. Contribution to society

   As a corporate citizen that is a member of society, we shall strive to co-exist with local communities and actively engage in activities that contribute to society at large.

   • 7-1　We shall contribute as a member of society

     ○　We shall respect the culture and customs of local communities and strive to expand opportunities for communication, so as to ensure that the Group’s business activities will be welcomed, popular, and trusted by local communities. We shall also contribute to the development of local communities through participation in local organizations, and participation and cooperation in social contribution activities such as volunteer activities.

     ○　In the event of a large-scale disaster such as an earthquake and wind or flood damage, the entire Group shall cooperate to promptly restore the social infrastructure.

   • 7-2　We shall promote initiatives to address social issues

     ○　We endorse the SDGs and other ideas adopted at the UN Sustainable Development Summit as international goals for a sustainable and better world, and we shall work on measures for gender equality such as promoting the active participation of women in the workplace and encouraging men to take child care leave.

8. Blocking relations with anti-social forces

   We shall not have any relations with anti-social forces or groups that threaten the order and safety of civil society.

   • 8-1　We shall block relations with anti-social forces

     ○　We shall not have any relations with anti-social activities or forces that threaten the order and safety of civil society or hinder economic activities.

     ○　If we are subject to unreasonable demands from anti-social forces or groups, we shall firmly reject such demands and we shall not settle the matter by offering monetary or other benefits.
     We shall not engage in any transactions with anti-social forces or business partners that have relations with anti-social forces. In the unlikely event that a business partner has relations with anti-social forces, we shall immediately suspend transactions with such business partner.

9. Contribution to the international community

   In response to the globalization of our operations, we shall not only comply with the laws of each country and region and respect various international standards, but also contribute to the economic development of those countries or regions while respecting their cultures and customs.

   • 9-1　We shall comply with the laws and regulations of each country and contribute to the economic development of that country or region.

     ○　We shall comply with applicable laws and regulations in each country and region, and promote sound business activities to contribute to the development of that country or region.

     ○　We shall maintain and promote friendly relations with local communities by actively communicating with each country and region and striving to respect human rights and understand their culture, customs, and traditions.

10. Responsibilities of officers and responding to issues

    In order to realize the spirit of this Charter of Corporate Behavior, the officers of each Group company shall take the initiative in ensuring that this Charter is thoroughly implemented within the company and that all related parties, including business partners, are familiar with the Charter. Furthermore, the officers shall constantly monitor internal and external opinions and develop effective internal systems.
    　In the event of a violation of this Charter of Corporate Behavior, the officers shall clarify the cause and responsibility, work to resolve the issue and prevent recurrence, and take strict disciplinary action, including on themselves.

    • 10-1　We shall establish a compliance system and systematically engage in compliance activities

      ○　In order to promote compliance activities as a Group, we have established a Compliance and Risk Management Committee and an Audit Office at Group headquarters, and internal audit divisions at key operating companies. We have also appointed an officer in charge of compliance, and the entire Group shall systematically work to improve and thoroughly implement a compliance system.

    • 10-2　We shall actively participate in education and training to acquire and improve our knowledge of compliance

      ○　We shall regularly and continuously provide compliance-related education in order to respond to revisions to laws and social demands in a timely and appropriate manner.

    • 10-3　Officers and managers shall submit compliance pledges

      ○　All Group officers and managers are strictly aware of the importance of compliance and pledge that they shall execute their duties in faithful compliance with laws and regulations.

    • 10-4　We shall work to enhance internal audits

      ○　The Audit Office shall regularly conduct internal audits in accordance with the Companies Act and the Financial Instruments and Exchange Act to confirm and evaluate whether each Group department and division is performing its work properly and in compliance with laws and regulations. We shall conduct extraordinary audits, point out flaws and corrective action, and follow up them as necessary to conduct effective audits.

    • 10-5　We shall proactively use the whistleblowing and “consultation system”

      ○　We shall establish an internal and an external whistleblower hotline for violations of laws and regulations. The external hotline shall be at a law firm, and the internal hotline shall be in the General Affairs and Human Resources Department at the Group headquarters and in the internal audit divisions at key operating companies. Furthermore, the General Affairs and Human Resources Department at the Group headquarters and the internal audit divisions at key operating companies shall accept consultations as a consultation hotline when employees have doubts about compliance with the Antimonopoly Act, the Construction Business Act, and other laws and regulations.

    • 10-6　Measures for violations

      ○　If officers or employees violate the Charter of Corporate Behavior, the Code of Conduct, or the Antimonopoly Act Compliance Manual, the Company shall take strict disciplinary action based on a resolution of the Board of Directors if a violation by an officer, or based on the employment rules if a violation by an employee, and top management shall personally strive to resolve the problem, investigate the cause, and prevent recurrence.

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