Manufacturing and distribution of film capacitors and electronics components

Basic CSR Policy

TOPEN TOPCompanyBasic CSR Policy

Basic CSR Policy

Revised March 25, 2022

The company group recognizes that compliance with laws and regulations required in the course of
business activities, and acting consistently with its management philosophy and in accordance with high
ethical standards are most important for it to fulfill its corporate social responsibility (CSR) so we have
established the Basic CSR Policy as follows.


Chapter 1    Labor

(Autonomy of employment)
Article 1     All group employees are employed at their own free will and will not be forced to work.

(Prohibition of inhumane treatment)
Article 2     The company group respects the human rights of group employees and prohibit harsh
                 and inhumane treatment, including abuse and the various forms of harassment.

(Prohibition of child labor)
Article 3     The company group does not employ children who have not reached the minimum
                 working age in the countries and regions where we conduct business activities, and
                 group employees less than 18 years of age do not engage in work that may impair their
                 development or endanger their health and safety.

(Prohibition of discrimination)
Article 4     The company group does not tolerate discrimination in hiring, promotion, compensation,
                 training and other aspects of employment due to factors other than those that are
                 reasonable such as a person’s ability, aptitude and achievements, and strives for the
                 realization of equal opportunity and fair treatment.

(Work hours)
Article 5     The company group properly manages the work hours, holidays and leave of group
                 employees so that legal limits in the countries and regions where we conduct business
                 activities are not exceeded.

(Appropriate wages)
Article 6     The company group pays group employees in compliance with all wage-related laws,
                 including the minimum wage, overtime, and statutory benefits in the countries and
                 regions where we conduct business activities. In addition, the company group does not
                 reduce wages unreasonably.

(Guarantee of the right to organize)
Article 7     The company group ensures the right of group employees to organize recognized in the
                 countries and regions where we conduct business as a means to realize labormanagement
                 consultation on matters such as the work environment and wage levels.

(Fair treatment)
Article 8     The company group creates an internal environment and promotes recruitment and
                 development aimed at the promotion to management of core human resources, including
                 women, non-Japanese employees and mid-career hires. In addition, the company group
                 strives for the realization of equal opportunity and fair treatment.

(Individual quality improvement and skill development)
Article 9     In addition to respecting the character, individuality and lifestyles of group employees,
                 the company group strives for the improvement of satisfaction by providing a workplace
                 culture that encourages the improvement of individual quality and skills.


Chapter 2    Labor

(Workplace safety)
Article 10   The company group evaluates the risks to workplace safety, and suppresses risks with
                 appropriate design, technology and management measures such as taking appropriate
                 safety measures with the machinery and equipment used at the company. In addition,
                 group employees must not be disadvantaged as a result of expressing concerns about
                 safety.

(Workplace health)
Article 11   The company group grasps situations in the workplace in which workers come into
                 contact with harmful organisms, chemical substances, noise, offensive odors, etc., and
                 takes appropriate measures.

(Occupational accidents and diseases)
Article 12   The company group builds procedures and systems to grasp and report the state of
                 occupational accidents and diseases. In addition, we take appropriate measures.

(Emergency response)
Article 13   In order to protect the people’s lives and physical safety, the company group builds
                emergency response measures assuming disasters and accidents that could occur, and
                makes them known thoroughly throughout the workplace.

(Consideration for work involving physical stress)
Article 14   The company group identifies work involving physical stress such as manual transport
                 work, heavy or repetitive lifting work, work carried out standing for long periods and
                 excessive repetitive assembly work, and manages it appropriately so that it does not lead
                 to accident or disease.

(Health and safety of facilities)
Article 15   The company group ensures appropriately the health and safety of facilities provided for
                 the daily life of group employees (dormitories, canteens, toilets, changing rooms, etc.).

(Health management of group employees)
Article 16   The company group carries out medical examinations at the level established by law,
                 etc., in the countries and regions where we conduct business activities, and implements
                 appropriate health management for all group employees.


Chapter 3    Ethical management

(Genuine management activities)
Article 17   The company group prohibits corruption, extortion and embezzlement (including the
promise, provision, supply or acceptance of bribes) in relationships with stakeholders. In
addition, all business transactions are executed transparently and reflected accurately in
books and records.

(Inappropriate offer or receipt of benefits)
Article 18   The company group does not supply or receive inappropriate benefits in relationships
                 with stakeholders. In addition, the company group maintains sound and normal
                 relationships with politics and administration, and does not engage in bribery or illegal
                 political contributions, etc.


(Prohibition of abuse of dominant bargaining position)
Article 19   The company group does not engage in actions that put suppliers to a disadvantage by
                 abusing its dominant bargaining position.

(Prohibition of acts that restrict competition)
Article 20   The company group does not engage in acts that impede fair, transparent and free
                 competition such as cartels or bid rigging.

(Prohibition of fraudulent transactions)
Article 21   The company group does not engage in insider trading or any fraudulent conflict-ofinterest
                 transactions.

(Provision of appropriate products and services)
Article 22   The company group pays close attention to compliance with related laws and
                 regulations, and the protection of the trade secrets of customers, and provides products
                 and services that are safe, useful and of high-quality to society.

(Provision of accurate information)
Article 23   The company group discloses to stakeholders information on our business activities,
                 structure, financial position and business results in accordance with related laws and
                 regulations, the market rules, etc., of the countries and regions where we conduct
                 business activities. The falsification of records or misrepresentation of conditions or
                 work in the supply chain is not allowed.

(Respect for intellectual property rights)
Article 24   The company group respects its own and others’ intellectual property rights, and
                 supplies technology and know-how in a form whereby intellectual property rights are
                 protected.

(Appropriate export control)
Article 25   The company group has established a clear control system for the export of technology
                 and goods regulated by laws and regulations in the countries and regions where we
                 conduct business activities, and implements appropriate export procedures.

(Prevention and early detection of misconduct)
Article 26   The company group conduct activities to prevent misconduct and establishes systems to
                 detect and respond to misconduct at an early stage.

(Prohibition of retaliation)
Article 27   The company group has built procedures that enable employees to express concerns
                 without fear of retaliation, such as the establishment of a fair internal reporting system,
                 and communicates these to group employees. In addition, the company group does not
                 tolerate any actions such as disadvantageous treatment or harassment of employee who
                 make reports.

(Responsible procurement of minerals)
Article 28   The company group procures from trusted suppliers so that the mineral resources such as
                 tantalum, tin, tungsten and gold in the products that we manufacture do not fund or
                 become profit sources, either directly or indirectly, for armed groups that are serious
                 abusers of human rights, and so that we do not promote inhumane acts such as violence,
                 looting, abuse, human trafficking or child labor through the use of conflict minerals.

(Elimination of antisocial forces)
Article 29   The company group takes decisive action against antisocial forces and groups that
                 threaten the order and safety of society, and cuts off all relationships with them. In
                 addition, the company group does not engage in any acts that benefit antisocial forces or
                 promote their activities.

(Protection of personal information)
Article 30   When collecting, storing, processing, transmitting or sharing personal information, the
                 company group complies with personal information protection acts and related laws and
                 regulations in the countries and regions where we conduct business activities, and
                 protects personal information appropriately with regard to all of the people with whom
                 we carry out business.

(Contributions to local communities)
Article 31   We respect the cultures and customs of the countries and regions where we conduct
                 business activities, and strive to contribute to local communities through participation in
                 various events, environmental conservation activities, the creation of employment, etc.


Chapter 4    Environmental protection

(Establishment of environmental management systems)
Article 32   The company group strives for the continuous improvement of
                 environmental management systems while running the PDCA cycle through
                 activities based on ISO 14001.

(Environmental protection and the reduction of environmental impacts)
Article 33   The company group strives for environmental protection and the reduction of
                 greenhouse gas emissions by resource-saving, energy-saving, the use of sustainable
                 resources, minimization of waste, prevention of pollution and the reduction of emissions
                 of global warming substances and hazardous substances throughout the lifecycle of our
                 business activities, from the procurement of raw materials and parts, to production and
                 distribution.

(Compliance with environmental laws, regulations, standards, etc.)
Article 34   The company group complies with laws, ordinances, agreements, etc., regulated by laws
                 and regulations in the countries and regions where we conduct business activities, and
                 strives for environmental protection by establishing voluntary management standards as
                 required.


Chapter 5    Information security

(Building of information security systems)
Article 35   The company group builds information security systems to maintain and improve
                 appropriate security levels, and strives for their continuous improvement.

(Establishment of internal regulations)
Article 36   The company group establishes internal regulations and guidelines based on this basic
                 policy, and presents clear guidelines with regard to the handling of information assets.

(Legal compliance)
Article 37   With regard to the handling of information, group officers, employees, etc., comply with
                 laws and regulations related to the protection of information, internal policies and
                 regulations.

(Education and enlightenment activities)
Article 38   The company group implements continuous education and enlightenment activities for
                 group officers, employees, etc., to improve awareness of information security.


Chapter 6    Crisis management at times of disaster

(Building of disaster countermeasures systems)
Article 39   The company group builds and maintains a crisis management system to minimize the
                 impact if natural phenomena such as earthquakes, wind and flood damage, etc., or manmade
                 disasters such as facility accidents occur.

(Liaison system)
Article 40   If a disaster occurs, the company group shares information in accordance with the
                disaster countermeasures routes established in internal regulations, and promotes early
                recovery.

                                                                                                                                                  End



History
April 1, 2005             Enactment
February 12, 2010     Revised in association with a revision of organizational rules
March 11, 2010         Revised the subject at the beginning
April 1, 2016             Revised due to change of president
March 25, 2020         Integrated with the Basic Compliance Policy and changed the title from the Okaya
                                Group CSR Policy
                                Added content on environmental protection and information security
March 25, 2022         Added Article 8, added greenhouse gas to Article 33, added etc., to Articles 37
                                and 38, added Chapter 6 “Crisis management at times of disaster”