Kasai North America, INC.

Corporate Ethics & Responsibilities

Code of Conduct

Message from the Chairman

It is essential to the success of our Company to act responsibly and in compliance with the law. But my commitment to compliance goes beyond merely complying with the law. One of my most important roles is to help create the best possible work environment for everyone in our Company. We should have the comfort of knowing that we work in a safe and ethical workplace and conduct business in a way that makes us proud. My hope is that we are proud to work here, feel good about our jobs, and attain our highest productivity.

Every person, regardless of position, shares in this responsibility. That is why it is so important that we all do our part to achieve this commitment. One incident, one news story, one careless comment, and what we have worked so hard to achieve can be lost. That is why the way we conduct our business is as important as the products we sell.

Our Code of Conduct provides us with resources and information to operate our business ethically and in compliance with laws. It is intended to help us make good decisions on the job every day. A strong company is built on good decisions made through discussions with others, so you should never feel alone when facing an ethical dilemma. Speak up if you have a concern or see a problem, and seek guidance anytime you are unsure about the right thing to do.

Our continued success depends on each and every one of us consistently doing what is right. We want to be proud not only of our achievements but also of how we achieve success. Our Code of Conduct represents fundamental characteristics of the way we will operate our business – our KNA DNA.

Thank you for your commitment to compliance and ethics.

Code of Conduct

Code Of Conduct

Supporting Diversity, Inclusion, and Human Rights

At Kasai, we are all part of one team, but we represent many different ideas, experiences, and backgrounds. We value our employees’ unique contributions and believe that everyone should have an equal chance to succeed. We must continually strive to hire and promote a diverse workforce so that we can realize the benefits of distinct ideas and perspectives. We also recognize our responsibility to take steps to ensure that employees around the world are treated with dignity and respect.

For additional details on our Diversity and Inclusion policy, please refer to our Code of Conduct.

Code Of Conduct

Trade Obligations

Trade Restrictions, Embargo, and Boycotts

At Kasai, we are committed to complying with all trade restrictions and boycotts imposed by the government. Such restrictions prohibit our Company from engaging in certain business activities in specified countries and with certain individuals and businesses. For example, these individuals or businesses include identified terrorist organizations and narcotics traffickers.

Human Rights

Kasai is strongly committed to fair employment practices everywhere we operate and across our entire supply chain. We will not knowingly conduct business with any individual or company that participates in the exploitation of children, physical punishment, forced or prison labor, or human trafficking. We expect that our suppliers, vendors, and customers share our commitment to these same standards. You must be alert to potential abuses and speak up if there is a suspicion of possible human rights violations.

For additional details on our Trade Obligations and Human Rights policies, please refer to our Code of Conduct.

Code Of Conduct

Business Ethics

Anti-Corruption and Anti-Bribery

Kasai prohibits all forms of corruption and bribery and will take all necessary steps to eliminate corruption and bribery in our business activities. This prohibition not only applies to our employees, but it also applies to any third party representing us or acting on our behalf. These obligations apply in all cases, but are especially strict in matters involving government officials. Our commitment to anti-bribery applies, without exception, to all of our operations, regardless of the local laws or cultural practices. For additional details on our stance on Anti-Corruption and Anti-Bribery, please refer to our Code of Conduct manual.

Antitrust and Fair Competition

Kasai is committed to dealing with others ethically and with integrity. Our reputation depends on our ability to maintain our integrity at all times. Every business decision we make must comply with the law and reflect our high ethical standards. Kasai will compete vigorously while strictly complying with all applicable antitrust laws. We will not engage in any activities that violate these laws such as agreeing with our competitors to fix prices, discounts, or terms of sale, limit production, divide markets, coordinate bidding activities, or boycott customers or suppliers. For additional details on our stance on Antitrust and Fair Competition, please refer to our Code of Conduct manual.

Ethical Business Dealings

Kasai values our partnerships with our customers, suppliers, and vendors. We will deal fairly with them and treat them with respect. To fulfill this commitment, Kasai employees must not engage in any unfair, deceptive, or misleading practices. Employees must always present our products and information in an honest and forthright manner. Employees must be fair, factual, and complete in our sales and promotional materials, and must provide only truthful information about our products and not make disparaging remarks about our competitors. For additional details on our stance on Ethical Business Dealings, please refer to our Code of Conduct manual.