East Nippon Expressway Company Limited

Expressway service

NEXCO EAST

Compliance

On June 27, 2011, the Board of Directors of East Nippon Expressway Company adopted this NEXCO East Group Code of Conduct. This NEXCO East Group Code of Conduct set forth the basic internal standards to be observed by all directors, officers and employees of NEXCO East Group. For the purpose of this Code, “NEXCO East Group” means: (1) East Nippon Expressway Company, and (2) any subsidiary which is under consolidated financial statements of East Nippon Expressway Company.

Based on this Code of Conduct, NEXCO East Group has established and maintained a compliance program including internal company rules, a Compliance Commitee and a hotline reporting system independent of ordinary reporting structures.

NEXCO East Group Code of Conduct

1 Basic policy of Business Conduct.

Expressway is an important infrastructure deeply rooted in people's lives, contributes to development of culture and industry of our country for a long time into the future.

NEXCO East Group is on a mission through efforts to provide and make effective use of expressway space with safety, security, comfort and convenience that contribute to improving the quality of people's lives and the sound development of the national economy. We seek to be an entity that is trusted by and always be in harmony with society through fulfilling its social responsibility as a good corporate citizen in all aspects such as social, economic and environmental.

In order to solidify the trust of society and to fulfill our corporate social responsibility, NEXCO East Group acts in compliance with laws and regulations in Japan and overseas, establishes high ethical standards, and acts based on the principle of equity, fairness and integrity.

Directors and officers of NEXCO East Group recognize their roles in realizing the spirit of this Code of Conduct, take the leadership in their actions and set up an effective system throughout the company to comply to the code. In the event this code is violated, they should take initiative to identify the cause of the infringement, take measures to prevent recurrence and achieve accountability.

2 Our Code of Conduct.

  • (1) Compliance with the rule
    1. More than complying with all applicable laws and regulations, internal rules and rules of the society, we shall conduct our business activities in a higher ethical manner.
    2. In view of the public nature of the expressway business, we purport to act on equity , fairness and integrity.
  • (2) Respect for Human Rights
    1. We shall respect the basic human rights of all people and shall refrain from indulging in any discriminatory practice based on race, color, national origin, religion, political beliefs, creed, occupation, sex, origin, family, disability and age.
    2. We shall neither conduct any harassment nor any behavior hurting the dignity of individuals based on sex, authority and position.
    3. We shall not use any form of forced labor or child labor.
  • (3) Relationships with customers
    (Attitude to customers)
    1. We shall put first priority on customers and always think what to do to improve their “safety, security, comfort and convenience” which is the basis of our business activities.
    2. We shall endeavor to prompt and appropriate responses to customers’comments and questions.
  • (Protection of Personal Information)
    1. We shall recognize the importance of protecting personal information and the personal information carefully and properly not to infringe induvidual’s right and interest.
    2. In order to prevent leakage or loss of the personal information, we will safeguard such information.
  • (4) Relationship with business partners
    1. We shall conduct our business activities in compliance with equal, fair and transparent procedures at all times.
    2. We shall conduct a strict compliance with the Antimonopoly Act and the Act concerning the Elimination and Prevention of Involvement in Bid Rigging, etc.
    3. We shall neither receive nor offer any illegal payments, gifts or entertainment from or to our business partners utilizing our position.
  • (5) Relationship with Shareholders and Investors
    (Responsibility to Shareholders and Investors)
    Through the efforts of strengthening its financial position by endless streamlining, development of new business, and improving brand name, we shall pursue our corporate value enhancement.
  • (Disclosure of Information)
    Through promoting communication with shareholders and investors and with appropriate disclosure of corporate information, we shall endeavor to increase transparency of our business activities.
  • (6) Relationship with society
    (Responsibility to the local community)
    We shall conduct business while achieving greater cooperation with local communities, in close contact with the life of the people of the community, we contribute to the development of local communities as a "good corporate citizen"
  • (Conservation of road assets, etc.)
    1. We shall strive to better manage and operate expressways and related facilities, which are an important infrastructure for the improvement of people's lives and the development of the national economy, in good condition and inherit them to the next generation.
    2. We shall strive to manage properly of all tangible and intangible assets of the company including the company's brand and intellectual property and to improving their value.
  • (Response to anti-social forces)
    1. We shall take a strong stand and cut off any relationship with anti-social forces and organizations that pose a threat to civil society.
    2. We shall take a strong stand against users who fail to observe the traffic rules of expressways.
  • (Responsibility to the international community)
    1. We shall comply with the applicable laws and regulations of the country or region which we do business, we shall respect international norms including human rights.
    2. We shall respect the culture and customs of each country and region, we shall conduct business on a foundation of trust with our stakeholders.
    3. We shall never commit illegal activities such as to give, offer or promise to give profit or benefit to foreign public officials in order to gain illegal benefits in international transactions.
  • (7) Relationship with the environment
    1. In order to reduce the environmental impact associated with our business activities, we shall strive to reduce the generation of waste and to save and re-use of such resources.
    2. We shall strive to keep business activities that are concerned about the conservation of biodiversity and healthy ecosystems in the region.
  • (8) Relationship with employees
    1. We shall strive to promote the formation of a gender-equal society that respect for human rights, diversity, personality, and individuality and to create a work environment that does not allow any discrimination or harassment based on sex, age and physical disability.
    2. We shall strive to create a safe and clean work environment.
    3. We shall strive to create a corporate culture that employees can feel job satisfaction through challenging to new business with pride of professional and with innovative mind.
  • Four guidelines when we encounter with situations in doubt

    When we are not sure what to do, we will decide based on the check list below.

    1. Compliance with the applicable laws or rules
    2. Influence to the trust and the brand of the NEXCO East Group
    3. Decision on sufficient information and due diligence
    4. Explicability to our family and friends without any guilty feelings