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Toshiba Group Standards of Conduct

These Toshiba Group Standards of Conduct have thus been established in order to make our management principles and management vision a reality and as a basis to guide our activities so that we can operate under the principles of fairness, integrity and transparency and contribute to the formation of a sustainable society.

Introduction

As the Toshiba Group looks to become an enterprise trusted by society, we have set up management principles respecting humanity, creating new values, and contributing to the lives and cultures of different countries around the world. At the same time, we operate our business under a management vision in which we aim to make adequate profits and sustainable growth and to bring our customers comfort and joy through the professional expertise and actions of each of our personnel and the collective efforts of our people. These Toshiba Group Standards of Conduct (hereinafter called the “SOC”) have thus been established in order to make our management principles and management vision a reality and as a basis to guide our activities so that we can operate under the principles of fairness, integrity and transparency and contribute to the formation of a sustainable society. Each of the directors, corporate auditors, and officers (hereinafter called the “Directors”) and employees (hereinafter called the “Employees”) of Toshiba Group should comply with the SOC and strive to operate a sound and high quality business as a part of a global enterprise which emphasizes a balance between the environment, human rights and local communities under the principle of giving the highest priority to life, safety and compliance with laws, regulations, social norms and ethics.

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Chapter 1   SOC for Business Activities

1. Customer Satisfaction

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall supply products, systems and services (hereinafter called “products and services”) that are based on voice of customer and comments and that satisfy customer needs and requirements, and which comply with laws, regulations and contracts.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. supply safe and reliable products and services;
  2. provide reliable information regarding products and services in an appropriate manner;
  3. respond to requests and consultations from customers in an honest, prompt and appropriate manner;
  4. respect voice of customer and endeavor to develop and improve products and services that satisfy customer needs; and
  5. properly collect, use and manage customers' personal data.

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2. Production and Technology, Quality Assurance

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall:

  1. observe all applicable laws and regulations, as well as contracts related to production, technology and quality assurance; and
  2. promote constant technological innovation and product improvement and supply safe and high quality products and services that meet customers' needs and incorporate the most advanced technologies.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. assure the fulfillment of warranty commitments, with priority given to customer satisfaction, and ensure the safety of products;
  2. promote the research and development of advanced technologies, products and services, and the continuous improvement of technology infrastructure; maintain basic technological and functional infrastructure so as to respond in a timely and appropriate manner to changes in the technological environment and to develop products and services that effectively utilize advanced technologies;
  3. in undertaking production and technology-related activities, seek to secure and exploit intellectual property rights for Toshiba Group, while fully respecting the legitimate intellectual property rights of third parties. Directors and Employees shall not acquire third-party proprietary information by improper means, nor disclose or divulge to others trade secretsNote1, whether belonging to Toshiba Corporation, a Toshiba Group Company or a third party, without first obtaining the appropriate approval; and
  4. in case they obtain information regarding accidents involving any products and services, or the safety of any products and services, verify the facts of such information instantly and take appropriate measures based on such verification.
Note1:
Herein, “trade secrets” means trade secrets, know-how and other technical or business information which is used in business activities and is maintained as confidential.

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3. Marketing and Sales

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall:

  1. deliver superior products and services that meet customer needs and requirements, and conduct marketing and sales activities in compliance with all applicable laws and regulations; and
  2. recognize the value of information as an asset and endeavor to protect information on third parties (including trade secretsNote2 of other companies and personal data) obtained through marketing and sales.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. follow sound and fair business practices in all dealings with customers;
  2. promote marketing and sales that comply with all applicable laws and regulations, observe sound business practices and respect socially accepted ideas;
  3. observe the SOC on “Competition Law” and endeavor to practice and promote free and fair competition;
  4. if the customer is a governmental agency (hereinafter whether domestic or foreign, and including enterprises owned by national or local government), comply with the company rule on marketing activities toward governmental agencies and not engage in any illegal activities, such as bid obstructionNote3 or competitor coordination on orders Note4, related activities or activities that may result in suspicion of engaging in such activities; and
  5. acquire information on third parties only from legitimate sources and manage it properly and not disclose such information to any third party without first obtaining the appropriate approval.
Note2:
Herein, “trade secrets” means trade secrets, know-how and other technical or business information which is used in business activities and is maintained as confidential.
Note3:
Herein, “bid obstruction” means, when dealing with a governmental agency, inquiring about the agency's intentions regarding which prospective bidder will be contracted or the possible bid price, or acting in order for the agency to realize its such intentions.
Note4:
Herein, “competitor coordination on orders” means exchanging information or coordinating with competitors regarding which prospective bidder will be contracted, bid prices and other information.

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4. Procurement

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall:

  1. comply with all applicable laws and regulations and pay due consideration to the environment; and
  2. provide suppliers (hereinafter including prospective suppliers) with equal opportunities for transactions with Toshiba Group.
  3. endeavor to establish better partnerships with suppliers based on mutual understanding and trust.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. prioritize suppliers who meet the following requirements:
    • comply with laws and regulations, emphasize consideration towards environment and have excellent technical ability
    • reasonable and economically rational pricing
    • have a stable supply, flexibility to address fluctuations in demand and supply and sound management
  2. prior to procurement of necessary goods and services, undertake a comprehensive and fair evaluation in accordance with the standards set forth below:
    • environmentally friendly
    • appropriate quality and reasonable and economically rational pricing
    • deliver on schedule and with a stable supply
  3. refrain from receiving any personal benefits from suppliers with regard to corporate procurement, and fulfill contractual obligations to suppliers in good faith, ensuring that all transactions fully comply with ethically sound commercial practices, and with all applicable laws and regulations to protect suppliers;
  4. never employ illegal means to obtain confidential information from suppliers or other third parties in the course of procurement activities, and avoid disclosing proprietary information about Toshiba Group suppliers and third parties without first obtaining the appropriate approval; and
  5. ensure that all purchases are authorized by the relevant purchasing, procurement, or subcontractor departments.

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5. Environment

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall:

  1. strive to promote a sustainable environment with the recognition that the Earth is an irreplaceable asset and that there is a collective obligation to leave it to future generations in a sound state;
  2. comply with international, regional and national standards, laws, regulations, agreements, industry guidelines and company rules related to the environment;
  3. contribute to society by developing and offering excellent products that incorporate technologies for environmental protection; and
  4. strive to reduce the environmental impact of business activities.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. endeavor to do research and development activities and product manufacturing that support the reduction of the impact on the environment, and also work proactively to maximize the efficient use of energy, reduce the use of natural resources and recycle in the course of all business activities in order to prevent global warming and efficiently use resources;
  2. continually improve environmental activities by implementing action plans from both short-term and long-term perspectives through daily operations;
  3. conduct periodic measurements and inspections, and maintain records accordingly. When there is an irregularity, promptly take corrective and preventive measures;
  4. perform timely and appropriate environmental impact assessments during the planning of new plants and plant relocations investment in production facilities, product planning and design and the purchase of new parts, components or materials;
  5. try to avoid the use or emission of any substance that, although not prohibited by applicable laws or regulations, is recognized as a threat to the environment by the government or public environmental authority of any country or region in which Toshiba Group operates. If such a substance should be used by Toshiba Group Companies, for whatever reason, every effort shall be made to minimize its environmental impact, through application of the best available technology and know-how; and
  6. try to maintain good and open communication channels such as disclosure of sufficient information regarding our environmental activities.

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6. Export Control

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall:

  1. refrain from any transactions that may undermine the maintenance of global peace and security;
  2. comply with all applicable export laws and regulations in each country and region of operation, and with those of the Unites States if we are engaged in transactions involving U.S. products and technological information; and
  3. prepare and implement export control compliance programs (hereinafter called the “Export Control Programs”) that stipulate corporate policies and procedures for assuring compliance with the foregoing laws and regulations.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. refrain from any transactions that may undermine the maintenance of global peace and security or any product or technology transactions that may violate the following laws and regulations:
    • all applicable export control laws and regulations in each of the countries and regions where Toshiba Group operates
    • the export control laws and regulations of the United States applicable to transactions involving U.S. products and technological information;
  2. assure strict management of transactions, from the initial inquiry through the delivery of products and services, by observing the detailed procedures for control of transactions stipulated in the Export Control Program; and
  3. prevent our products being used for development and manufacturing of conventional weapons and weapons of mass destruction by verifying the end use and the end user of products and technology.

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7. Competition Law

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall:

  1. comply with any and all laws and regulations enacted for the purpose of maintaining free and fair competition (hereinafter called “Competition Laws”); and
  2. prepare and properly implement Competition Laws compliance programs and company rules on marketing activities toward governmental agencies that set out corporate policies and procedures for assuring compliance with applicable Competition Laws and related regulations.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. observe the Competition Laws compliance programs as well as the company rules on marketing activities toward governmental agencies and promote free and fair business activities;
  2. avoid agreements or understandings with competitors relating to pricing (including quotations and bids), the volume of production and sales, allocation of markets, customers or territories, or restrictions on production capacities or technology. The prohibition of such agreements is not limited to those actually recorded in writing by way of memoranda or minutes, but also extends to oral agreements;
  3. if the customer is a governmental agency, observe the company rules on marketing activities toward governmental agencies and not engage in activities such as bid obstructionNote5 or competitor coordination on ordersNote6;
  4. not engage in activities or organize or participate in meetings, make pledges or arrangements, or exchange information which may be a cause of concern in respect of paragraphs 2 and 3 above, or engage in any related activities or activities which may result in suspicion of engaging in such activities;
  5. not require distributors or dealers to agree to or maintain resale prices for any Toshiba Group Company product; and
  6. not allow third parties (including sales representatives) to engage in activities prohibited under paragraphs 2 to 5 above.
Note5:
Herein, “bid obstruction” means, when dealing with a governmental agency, inquiring about the agency's intentions regarding which prospective bidder will be contracted or the possible bid price, or acting in order for the agency to realize its such intentions.
Note6:
Herein, “competitor coordination on orders” means exchanging information or coordinating with competitors regarding which prospective bidder will be contracted, bid prices and other information.

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8. Government Transactions

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall engage only in conduct that does not violate local laws, regulations, company rules on marketing activities toward governmental agencies or breach the terms of any contract with a governmental agency.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. not provide false information, such as false estimates of contract prices, to any governmental agency or its officials (hereinafter including past officials);
  2. not engage in bid obstructionNote7 or any related activities or any activities that may result in suspicion of engaging in such activities;
  3. not engage in competitor coordination on ordersNote8 or any related activities or any activities that may result in suspicion of engaging in such activities;
  4. refrain from making improper payments to any governmental agency or its officials, such as entertainment, gifts or gratuities prohibited by the SOC for “Improper Payments”;
  5. not disclose confidential information received from government sources in such a manner as to breach any obligation of secrecy; and
  6. when hiring former government officials, strictly examine the candidate in accordance with laws and regulations and internal regulations of the governmental agency in which he or she worked, and, after hiring such candidate, not allow him or her to engage in marketing activities for such governmental agency.
Note7:
Herein, “bid obstruction” means, when dealing with a governmental agency, inquiring about the agency's intentions regarding which prospective bidder will be contracted or the possible bid price, or acting in order for the agency to realize its such intentions.
Note8:
Herein, “competitor coordination on orders” means exchanging information or coordinating with competitors regarding which prospective bidder will be contracted, bid prices and other information.

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9. Improper Payments

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall observe prohibitions on payments illegal or improper under generally accepted sound business practices.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. neither make nor offer, either directly or indirectly, any payment or anything of value, whether in the form of compensation, business entertainment, gift, contribution, gratuity, or other form, that is illegal or unacceptable under generally accepted sound business practices, in any dealings with any governmental agencies, their officials, or members of any political party (including holders of a political office or candidates for such office);
  2. refrain from offering cash or other benefits to representatives of foreign governments as a means to gain unlawful benefits or profits when conducting international business transactions;
  3. ensure that reasonable compensation and all necessary terms and conditions are specified in advance when working with intermediaries, such as distributors or agents, and observe all measures required by the applicable laws and regulations of each country or region for such compensation;
  4. respect the established practices of any customer, government entity or other party, as well as all applicable laws and regulations, regarding the provision of or the restrictions or controls over the acceptance of business entertainment, gifts or other business courtesies by its employees or officials; and
  5. refuse participation or contributions by antisocial groups (i.e., groups that engage in any type of criminal activity or are deemed otherwise to be disruptive or pose a threat to society) in our business activities, and not promote their activitiesNote9.
Note9:
Herein, “promote their activities” means subscription to or purchase of publications or books, purchase of goods, endorsement by advertisement, offering of services, offering of cash or goods, and any other activities providing favors or benefits.

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10. Engineering Ethics

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall:

  1. engage in technology activities with a high level of ethics; and
  2. comply with all applicable laws, regulations and contracts.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. utilize their expertise, skills and experience to contribute to the health and happiness of humans and the safety of society;
  2. rely on scientific facts and recognize changes in laws, regulations, and conventional wisdom to make fair and independent judgments and act honestly with good faith;
  3. continuously seek to improve their expertise and capabilities to create new and innovative technology and offer safe and excellent products and services;
  4. endeavor to foster future engineers and bestow technology to them;
  5. promote more active communication with relevant parties to create an open-minded and transparent working environment; and
  6. fully comply with confidentiality obligations in relation to information obtained through customer contracts, and not disclose or divulge the Toshiba Group's confidential information to any third parties without prior approval.

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11. Intellectual Property Rights

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall:

  1. observe laws and regulations associated with patent law, copyright law and other intellectual property rightsNote10 laws; and
  2. protect the results of intellectual activities with intellectual property rights, make extensive use of those rights, and respect the legitimate intellectual property rights of third parties.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. proactively acquire and utilize intellectual property rights in order to strengthen business competitiveness;
  2. understand and observe company rules providing that intellectual property rights in respect of any invention, utility model, design for or actual work, such as mask work (i.e., the layout of an integrated circuit chip), computer program or digital content, that is determined to have been made by anyone during the period of his or her services for or employment by a Toshiba Group Company, and the ability to apply for such rights, belong to the Toshiba Group Company;
  3. adequately maintain intellectual property rights and take appropriate measures against infringement of these rights by a third party;
  4. respect and take due care of the legitimate intellectual property rights of third parties; and
  5. not acquire, use or disclose trade secretsNote11 of Toshiba Group Companies or third parties without authorization.
Note10:
Herein, “intellectual property rights” means patent rights, utility model rights, design patent rights, trademarks, copyrights, mask work rights, trade secrets, and any other such rights.
Note11:
Herein, “trade secrets” means trade secrets, know-how and other technical or business information which is used in business activities and is maintained as confidential.

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12. Accounting

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall comply in full with any laws or regulations regarding accounting and conduct proper accounts management and financial reporting.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. maintain proper and timely accounts, and shall not report inaccurate information on accounts or provide misleading financial reports; and
  2. endeavor to promote the prompt release of accurate accounts by maintaining and improving the accounting management system.

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13. Corporate Communications

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall:

  1. endeavor to obtain the understanding of stakeholders, including customers, shareholders and the local community, in respect of corporate activities, products and services, and further improve public recognition of Toshiba Group and its corporate image by means of positive and timely corporate communications activities on business informationNote12, such as corporate strategy and financial data; and
  2. ensure that management policies are well informed in the company, and promote information sharing as a means of raising morale and creating a sense of unity.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. conduct corporate communications with integrity on the basis of objective facts;
  2. conduct corporate communications by appropriate means, to enable customers, shareholders, potential investors and the members of the community of each country or region to obtain a reasonable understanding of Toshiba Group's activities; and
  3. obtain prior consent from the persons responsible for corporate communications before disclosing business information to analysts and to the media, including newspapers, magazines and television stations.
Note12:
Herein, “business information” includes any information regarding actions, or activities which may raise the suspicion of such actions, prohibited by these SOC (hereinafter called “Risk Compliance Information”).

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14. Advertising

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall:

  1. use advertising activities to increase public awareness of the Toshiba brand and public awareness of, and trust in, Toshiba Group; and
  2. seek heightened awareness of Toshiba Group as a global company and a “good corporate citizen” at national and regional levels.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. increase public trust in the Toshiba brand and acquire the good will and trust of the people in each of the countries or regions in which Toshiba Group operates, thereby creating an environment whereby sustained business development and sales promotion activities may be achieved;
  2. not use advertising to cast third parities in a negative light, in an attempt to make Toshiba Group appear more favorable, or for any other negative purpose; and
  3. not make reference to politics or religion in advertising, cause offense or show disrespect by implying discrimination based on race, religion, sex, national origin, physical disability or age.

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Chapter 2   SOC for Corporate and Individual Relationships

15. Human Resources

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall:

  1. accept the different values of individuals and respect differences in character and personality based on a fundamental respect for human rights;
  2. respect basic human rights on top of observing laws and regulations, and shall not engage in acts of discrimination or condone use of either child labor or forced labor;
  3. as enterprises, respond promptly to any acts within Toshiba Group that infringe upon basic human rights and act resolutely to ensure the termination of such infringement;
  4. develop a working environment where Employees may perform their duties creatively and efficiently so that they may achieve a work/life balance (i.e., balance between work and home); and
  5. endeavor to ensure a safe and comfortable working environment for Employees.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. act responsibly as self-reliant members of the company and of society with integrity and common sense;
  2. accept and accommodate different values, and respect the character and personality of each individual, observe the right to privacy and human rights of each individual, avoid any discriminatory actions based on race, religion, sex, national origin, physical disability, age or sexual orientation, and avoid physical abuse, sexual harassment, power harassment (i.e., bullying or harassment by superiors in the office) or violation of the human rights of others;
  3. accomplish their tasks to the utmost of their abilities, in light of their authority and the responsibilities assigned to them by the company, and endeavor to learn continuously and to improve their own abilities;
  4. realize employees' work/life balance through various ways of working so that they can maximize their capabilities to the fullest extent;
  5. cultivate a workplace environment that encourages the development of open-minded, cooperative and orderly work activities; and
  6. maintain safety, cleanliness and good order in the workplace and endeavor to prevent industrial accidents, and try to maintain good health.

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16. Corporate Information and Company Assets

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall:

  1. properly manage corporate informationNote13 and company assets (hereinafter including the Toshiba brand and other intangible assets);
  2. respect proprietary information and maintain corporate information as confidential, and prohibit disclosure or improper use of corporate information; and
  3. assure the proper protection of personal data throughout their business activities.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. not disclose or divulge corporate information, either during or after employment, without following appropriate internal procedures;
  2. not use corporate information or company assets to benefit themselves or any third party, to harm the interests of Toshiba Group, or for any other improper use, either during or after employment;
  3. not disclose or divulge to the company any confidential or proprietary information belonging to any third party acquired prior to their employment, in violation of their obligations to such third parties, including inter alia, former employees and clients;
  4. protect any personal data, in accordance with all applicable laws, regulations and company rules, including observance of lawful and appropriate procedures for obtaining and maintaining personal data, and use personal data only for appropriate purposes;
  5. not be party to any insider trading (i.e., using nonpublic corporate information in trading the shares or the like of a company);
  6. make use of corporate information in accordance with the rules on information security;
  7. endeavor to maintain company assets and not divert such company assets for any personal use;
  8. refrain from making improper use of company equipment and facilities; and
  9. not make unauthorized use of their position or authority within the company to benefit themselves or any third party or to impair the credibility or brand name of the company.
Note13:
Herein, “corporate information” means all information (hereinafter including information relating to third parties) that is handled by the Directors and Employees in the course of conducting business, except information open to the public.

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Chapter 3   SOC for Community Relations

17. Community Relations

1. Toshiba Group Corporate Policy

Toshiba Group Companies shall:

  1. contribute to and cooperate with all local communities in which Toshiba Group operates and perform its duties as a member of these communities;
  2. support Directors and Employees in undertaking voluntary activities and give full consideration to each individual's desire to exercise his or her civil rights;
  3. make appropriate donations in each country and region where Toshiba Group operates, after considering the contribution to the community, the public nature and the reasons for making donations; and
  4. try to improve the brand image in all aspects of their relationships with the communities.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. assure that Toshiba Group Companies undertake all activities in harmony with the community, by respecting the local culture and community traditions and customs;
  2. actively participate in developing communication with the local community, to encourage and maintain mutual respect and understanding;
  3. actively participate in community social activities and voluntary activities;
  4. pay due consideration on a daily basis to environmental issues, including global warming, and actively participate in environmental activities of local communities; and
  5. maintain integrity and common sense in all aspects of their relationships with these communities.

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18. Political Contributions

Toshiba Group Corporate Policy

Toshiba Group Companies shall not provide inappropriate benefits or favors to any politician or political organization.

2. SOC for Toshiba Group Directors and Employees

Directors and Employees shall:

  1. not make contributions to political parties or committees, unless permitted to do so by applicable laws, regulations, and company rules;
  2. not directly or indirectly engage in the activities described below on Toshiba Group's behalf, or by disbursing Toshiba Group funds, with politicians or political groups:
    • make loans (including personal guarantees) or sales under conditions more favorable than those normal for commercial practices; or
    • offer favorable benefits in the form of entertainment, gifts, or otherwise, except to the extent permitted by the applicable laws or regulations and ethical standards of the country or region concerned;
  3. not pay monies or offer benefits to any politicians (including former members of any legislative body, or current or former secretaries of any such politicians) or any company a politician may be involved with, whether such monies are in the form of commissions or consulting fees, in connection with marketing activities toward governmental agencies; and
  4. not allow third parties including intermediaries, such as distributors or agents, to engage in any activities described in paragraphs (1) to (3) above.

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Scope and Implementation

1. Scope of the SOC

  1. These SOC shall, on their adoption by each Toshiba Group Company by resolution of the board of directors or other appropriate corporate actions, apply to all Directors and Employees, including advisors and contract employees.
  2. Each Toshiba Group Company may modify these SOC upon their adoption for the reasons detailed below, but shall not make any modifications that contradict the general content and intent of the SOC:
    • to accommodate local laws and government regulations, business practices, labor practices, values or the like, traditional to the country or region.
    • to adopt SOC specific and appropriate to the company's field of business, products, services, and activities.

2. Implementation of the SOC

  1. Each Toshiba Group Company shall appoint a “Chief Implementation Administrator” to assume overall responsibility for implementation of the SOC. The Chief Implementation Administrator of Toshiba Corporation shall be the Chief Risk-Compliance Management Officer.
  2. Each Chief Implementation Administrator may appoint, as necessary, “Implementation Administrators,” who shall be responsible for the implementation of each article of the SOC. Within Toshiba Corporation, the Company President of each in-house company and the General Manager of each staff division shall assume the role of Implementation Administrator. In this capacity, they are responsible for implementation of the SOC in their in-house companies or divisions and also for guiding implementation in Toshiba Group Companies for which they are responsible.
  3. The corporate staff division of each Toshiba Group Company in charge of any of the items of these SOC shall formulate relevant rules or compliance programs and shall support that Toshiba Group Company's Implementation Administrators and any related companies by providing information and advice on formulating implementation rules and on developing educational programs.
  4. Toshiba Corporation's Corporate Representatives responsible for overseas business in their respective regions shall guide, support and cooperate with Toshiba Group Companies' overseas offices and subsidiaries in implementing the SOC in the businesses for which they are responsible.
  5. Toshiba Corporation's Corporate Social Responsibility Division and Legal Affairs Division shall be the bodies responsible for the maintenance of the SOC and the promotion and support for the adoption and implementation of the SOC by the Toshiba Group Companies.

3. In-house Information Reporting System and Protection of Information Providers

  1. Toshiba Group Companies shall establish an in-house information reporting system to ensure that Toshiba Group Directors and Employees are able to report Risk Compliance InformationNote14 directly to Chief Implementation Administrators or the division responsible for risk-compliance matters.
  2. Directors and Employees of each Toshiba Group Company are to report any Risk Compliance Information they have to their supervisors immediately or provide such information using the in-house information reporting system.
  3. The Chief Implementation Administrators, the divisions responsible for risk-compliance matters and supervisors who receive Risk Compliance Information must respond and act promptly and appropriately.
  4. Directors and Employees who provide Risk Compliance Information for good reason and in good faith must not be treated disadvantageously on the grounds that they provided such information.

4. Disciplinary Action

Any conduct in violation of these SOC shall be subject to disciplinary measures up to and including dismissal, according to and as set forth in each Toshiba Group Company's Disciplinary Rules/Staff Handbook.

Note14:
“Risk Compliance Information” means any information regarding actions, or activities which may raise the suspicion of such actions, prohibited by these SOC

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