From the time King Jim was established as a maker of office supplies in 1927,
we have continued to create products that can be used and enjoyed by all types
of people throughout society. As a result, our corporate value is now firmly
recognized and the King Jim name is respected and trusted by our many
customers.
In order for us to continue to serve society in the future, we must continue
to act in ways that enhance this corporate value. In this connection, all members
of the King Jim group of companies must forever strive to be worthy of society’s
trust and to be true to our corporate ethics. In January of 2003, the King Jim
group of companies adopted a policy of conduct geared toward observing management
concepts as well as corporate ethics, and, in order to create a system of compliance
in line with the concepts of this policy, we have established a compliance program.
Compliance of course requires adherence to applicable laws and regulations, but
it also means implementing corporate ethics and making positive contributions
to society. This involves nothing less than management that responds to the expectations
of all of our customers, shareholders, employees, transaction partners and other
stakeholders of the King Jim group of companies.
All executives and all employees of the King Jim group of companies must act
from the perspective of “compliance” now and in the future. I believe it is only
in this way that we will be trusted by society and be recognized as a company
of high corporate value.
September 16, 2004
King Jim Co., Ltd.
Representative Director/President Akira Miyamoto
COMPLIANCE PROGRAM
All of the corporate activities of the King Jim group of companies,
(the “King Jim Group”), must be grounded in “compliance.”
No individual member of our King Jim Group may act in a manner contrary to
corporate ethics or applicable laws. In the unlikely event that an employee becomes
aware of any act contrary to corporate ethics or applicable law, or any suspicious
act, such employee must take appropriate measures as set out in the compliance
system.
Each individual member of the King Jim Group must act in accordance with
all applicable laws and regulations, and with integrity.
No individual member of the King Jim Group may pursue profits in an improper
way, in violation of the spirit of “compliance.”
Guiding Principles for Compliance
Preservation of the Environment
Each member of the King Jim Group should strive to integrate in a positive way
activities from an environmental perspective and to reduce environmental burdens
on a global scale.
Prohibition Against Accepting or Offering Bribes
Each member of the King Jim Group should continue to maintain clean relationships
with others outside the King Jim Group and should not participate in any acts
that might sully the King Jim brand name, such as the acceptance or offering
of bribes or the like.
Creating Good International Transactional Relationships
Each member of the King Jim Group, in transacting with others domestically and
abroad, should strictly observe all applicable laws and regulations, and should
form good international transaction relationships by respecting the culture and
customs of his or her transaction partners.
Countermeasures Against Anti-social Forces
No member of the King Jim Group may have relations of any kind with anti-social
forces or groups, such as organized criminal groups or the like, and may not
respond in any fashion to illicit demands.
Strict Compliance with Antimonopoly Laws
Each member of the King Jim Group should strictly observe all applicable antimonopoly
and related laws and regulations and should compete in a fair, free and transparent
manner.
Respect for Intellectual Property
Each member of the King Jim Group should respect the intellectual property rights
of the King Jim Group, as well as the rights of others.
Prevention of Unfair Competition
Each member of the King Jim Group should strictly observe all applicable laws
relating to the prevention of unfair competition, and, in line with the spirit
of such laws, each member of the King Jim Group should strive to develop products
that demonstrate originality, and should always continue to seek the highest
reputation in the industry.
Respect for Fundamental Human Rights
Each member of the King Jim Group should uphold fundamental human rights, have
respect for others as people, and commit no acts that might injure the dignity
of others.
Respect for Labor-Related Laws and Regulations
Each member of the King Jim Group should strictly observe all applicable labor-related
laws, and should strive to maintain and improve a happy, safe work environment.
Prohibition Against All Forms of Harassment
No member of the King Jim Group may engage in any kind of harassment, sexual
or otherwise.
Prohibition Against Insider Trading
No member of the King Jim Group may engage in insider trading.
Appropriate Handling of Confidential Information
Each member of the King Jim Group should manage in an appropriate way all confidential
information, such as corporate secrets, know-how and personal information. No
member of the King Jim Group may improperly use any confidential information
or leak the same to third parties.