Introduction

K.SAKAI Group's business activities are based on relationships with suppliers in diverse countries and regions. While taking into consideration the characteristics of each industry, it is necessary to promote CSR initiatives in the supply chain as well. K.SAKAI Group aims to contribute to the realization of a sustainable society through its business activities, and to enhance the competitiveness and corporate value of K.SAKAI Group.
In April 2025, K.SAKAI Group formulated the “Supplier Code of Conduct for K.SAKAI & CO., LTD. and its direct and indirect subsidiaries” as part of its CSR initiatives in supply chain management, and summarized the initiatives we request of our suppliers. In order to conduct appropriate business activities, respect the human rights of stakeholders involved in our business, and protect the local environment, K.SAKAI Group asks suppliers to understand and practice the items listed below, and together with our suppliers, we aim to achieve coexistence and co-prosperity between our business activities and society/environment.

1. Respect the human rights of all of employees and do not engage in inhumane treatment.
2. Prevent forced labor, child labor and the payment of unfairly low wages.
3. Not engage in discriminatory employment practices.
4. Respect the rights of employees to associate freely in order to ensure open and fair negotiations between labor and management.
5. Provide employees with safe and healthy work environments.
6. Comply with all applicable local and international laws and regulations. Ensure compliance with fair business practices and anti-corruption, including prevention of conflicts of interest and anti-competitiveness.
7. Ensure the quality and safety of products and services.
8. Consider potential and existing impacts on local communities and the environment with regards to business activities. Take the necessary measures to prevent environmental pollution.
9. Disclose information on all items listed above in a timely and appropriate manner.

＜Cases of Material Breach＞
In the event of a material breach of the Supplier Code, K.SAKAI Group shall, upon verifying the facts, request that the supplier or other business partner improve the situation. If no improvement has been made after a specified period, we will take measures which may include reconsideration of the contract with the supplier or partner.
If necessary, K.SAKAI Group shall, along with experts designated by the Group, visit the site concerned for investigation.

Supplier Code of Conduct

In conducting your business activities, please comply with the laws, rules, and regulations of the national and local governments, respect internationally recognized codes of conduct, and observe each of the following standards. In addition, please ensure that your suppliers comply with this Code of Conduct and you obtain from your suppliers the information necessary to comply with this Code of Conduct. If these standards are not consistent with the laws and regulations of your country or region, we request that you apply more stringent standards.



1. Labor and Human Rights
(1) No Forced and Compulsory Labor
Employees must not be in any way restricted of their personal freedom of movement. Any person employed or engaged by our suppliers must have voluntarily chosen to do so. Any type of slave or forced, bonded or prison labor is prohibited. Suppliers must provide employees with advance notice of the employment conditions in a language the workers understand. Suppliers must not retain or otherwise destroy, conceal, confiscate, or prevent employees from using their passports, official identification cards, or other forms of employee identification or immigration applications.

(2) No Child Labor
Suppliers must not employ children under the minimum working age to work at any stage of production. In addition, suppliers must not employ young employees under the age of 18 to work night shifts, overtime, or other hazardous work that may harm the health, safety or morals of such employees.

(3) Adequate Working Hours
Supplier shall not have its employees work beyond the limits set by the laws and regulations of the region in which they work. Employees' working hours and holidays should be properly managed, considering international standards.

(4) Adequate Wage and benefit
Supplier shall comply with all applicable laws and regulations in the compensation paid to its employees (including minimum wage, overtime pay, and any legally mandated benefits or wage deductions).

(5) Prohibition of inhumane treatment
Suppliers must not expose their workers to harsh and inhumane treatment including any harassment, abuse, corporal punishment, mental or physical coercion nor to the threat of any such treatment. Facilities must be provided for the storage of personal possessions and valuables, as well as personal space of sufficient size to allow proper access.

(6) Prohibition of discrimination
Suppliers shall not engage in discrimination or harassment. Suppliers should also give due consideration, to the extent appropriate, to requests from employees regarding religious practices.

(7) Securing Employee Rights
Any person employed or engaged by Suppliers is entitled to form or join an employee organization (or union) of their choice with the aim of conducting collective bargaining and defending their interests. Suppliers must ensure that employees are able to communicate openly with management without fear of discrimination, retaliation, intimidation, or harassment, and that unlawful terminations are not made.


2. Health and Safety
(1) Occupational Safety
In order to ensure worker safety, Suppliers must assess the work environment and work conditions and take preventive and mitigating measures by appropriate technical and administrative means where there are hazards or potential hazards (e.g. chemicals, electrical and other energy sources, fire, vehicle and fall hazards, etc.).
In addition, appropriate and correct health and safety information and training, as well as the necessary protective equipment, should be provided to employees with respect to the risks associated with these hazards. Reasonable care shall be taken especially regarding pregnant and lactating female employees, employees with disabilities, and elderly employees.

(2) Preparing for emergencies
In preparation for emergency situations such as disasters or accidents that may impair human life and physical safety, Suppliers shall identify the possibility of occurrence and create action procedures for emergency measures that will minimize damage to employees and assets. Suppliers should install the necessary equipment, etc., and educate and train our employees to be able to take such actions in the event of a disaster.

(3) Prevention of occupational accidents and diseases
Suppliers must encourage employees to report, classify and record cases of occupational accidents and illnesses, investigate cases, and take steps to prevent them. Suppliers must conduct medical checks of employees in accordance with local laws and regulations.

(4) Consideration for physically demanding work
Physically demanding work shall be identified, evaluated, and properly controlled to prevent occupational accidents and illnesses.

(5) Safety measures for machinery and equipment
Suppliers should evaluate machinery and equipment used by its employees in the course of their work for safety risks and take appropriate safety measures.

(6) Facility health and safety
Proper health and safety must be ensured in facilities provided for employees living (dormitories, cafeterias, restrooms, etc.), as well as proper evacuation routes in the event of an emergency.

(7) Communication on health and safety
Suppliers should provide appropriate health and safety information education and training on the various hazards to which employees may be exposed in the course of their employment, in language and methods that employees can understand.

3. Protection of the environment
(1) Compliance with environmental permits, etc
In accordance with local laws and regulations, all required environmental permits, notifications, reports, etc., must be completed and kept up to date in compliance with operational and reporting requirements.
(2) Minimize Waste, Maximize Recycling
All business processes must minimize the use of natural resources such as water, fossil fuels, minerals, and native forest products, and must implement production, maintenance, equipment process changes, material substitution, reuse, conservation, and recycling to conserve resources and energy.

(3) Wastewater control
All wastewaters shall be monitored, controlled, and treated according to its characteristics before discharge or disposal to prevent the discharge of pollutants into the environment through wastewater.

(4) Air emissions control
Suppliers shall comply with relevant laws and regulations and implement appropriate measures to reduce emissions of hazardous substances into the atmosphere.

(5) Proper disposal of waste
Waste must be identified, managed, reduced, and disposed of properly. Suppliers must also strive to recycle.

(6) Management of chemical substances
In compliance with laws and regulations, chemicals and other materials that pose a hazard to human health or the environment shall be identified, labeled, and controlled to ensure safe handling, transfer, storage, use, recycling or reuse, and disposal.

4. Fair Business and Ethics
(1) Prohibition of corruption and bribery
Suppliers shall comply with all applicable anti-corruption legislation, especially to strictly prohibit all and any forms of bribery, corruption, embezzlement or extortion.

(2) Prohibition of anti-competitive behavior
Suppliers must not offer or condone promises, offers, or permission as a means of obtaining bribes or other undue or improper advantage.

(3) Appropriate information disclosure
All business transactions shall be conducted in a transparent manner, and information and records concerning business activities, including management and financial conditions, shall be properly disclosed and free from unauthorized alteration. In accordance with applicable laws, regulations, and industry practices, information regarding labor, health and safety, environmental activities, business operations, organizational structure, financial condition, and performance shall be disclosed in a timely and appropriate manner.

(4) Protection of intellectual property rights
Suppliers shall respect the intellectual property rights of third parties, including customers and suppliers.

(5) Protection of Whistleblowers
The confidentiality of information related to whistleblowing and the anonymity of whistleblowers shall be protected, and measures shall be taken to ensure that whistleblowers are not disadvantaged.

(6) Appropriate import and export controls
Supplies shall establish a clear management system and perform appropriate import/export procedures for the import/export of technology and goods regulated by laws and regulations.

(7) Minerals from the “Conflict Region”
Suppliers shall ensure that the 3TG (tantalum, tin, tungsten, and gold) and minerals such as cobalt, mica, aluminum, copper, lithium, and nickel contained in our products do not cause or contribute to human rights abuses, environmental destruction, corruption, or conflict in conflict zones and high-risk areas. Suppliers should ensure that our minerals do not cause or contribute to serious human rights abuse, environmental degradation, corruption, or conflict in conflict and high-risk areas.

5. Product safety and quality
(1) Ensuring product safety
Suppliers shall design, manufacture, and market products that meet the safety standards set forth by the laws and regulations of each country and ensure sufficient product safety.

(2) Provide accurate product and service information
Suppliers should provide customers and consumers with accurate information about their products and services.

6. Information Security
(1) Defense against computer network threats
Suppliers shall take protective measures against threats to computer networks and manage them so that neither we nor others are harmed.

(2) Protection of personal information
Suppliers must comply with the requirements of privacy and information security laws and regulations when collecting, storing, processing, transferring, and sharing personal information of customers, business partners, consumers, workers, and anyone else involved in their business activities.

(3) Prevention of leakage of confidential information
Confidential information received not only from the company but also from customers and third parties must be properly managed and protected.

7. Business Continuity Plan; BCP
Suppliers shall identify and evaluate risks that may impede business continuity, scrutinize their impact on business, and formulate a business continuity plan (BCP) that outlines necessary proactive measures over the medium to long term.

8. Contribution to society and local communities
Suppliers voluntarily engage in activities that contribute to the development of international and local communities by utilizing our own management resources.

Established in April 2025