POLA ORBIS Group

Code of Conduct

CONTENTS

174. Continuously Taking up New Challenges 　 Together with Clients

185. Further Utilization of New Values as Assets

196. Actions Full of Brand Pride

20Supplementary Provisions

21Check Column

163. Corporate Management Using Messages 　 with its own Sensibility and Words

3On formulation of POLA ORBIS Group Philosophy

5POLA ORBIS Group Philosophy

7Sustainability Statement

9POLA ORBIS Group Code of Conduct

9ⅰ.Purpose

9ⅱ.Definitions and Applicable Scope

10ⅲ.Points of Attention in Utilizing Code of Conduct

10ⅳ.Responsibilities of Management

152. Respect of Individual Sensibility

11Ⅰ．Actions to Sensitize the World to Beauty

111. Emphasis on Attractive Personality Full of Sensitivity

122. Creation of Values Desired by Customers

123. Development of Local Communities by 　 Utilization of "Beauty Creating Power"

134. Consideration for Beautiful Global Environment

141. Securing of Quality and Safety

14Ⅱ．Actions to Grow as Individuals and Group

Regional revitalization（Utilization of domestically produced raw materials）

Advanced technology（Quasi-drug active ingredient "NEI-L1"）

）trA fo muesuM aloP（ tra dna erutluC

On Formulation of POLA ORBIS Group Philosophy

In this age , i t becomes possible to obtain too much

information, causing the "meaning and purpose of what we do

now" to be missed. As a result, the corporate philosophy which

should be universal and the guidelines and strategy which

must be changeable lose their meaning in organizations. It is

not hard now to find "what must be done now" on the basis of

various information on the external and internal environments,

but this may be an easy goal or a simple method. It is also

possible to improve indexes of economic activities, such as

sales and profit, in a relatively easy manner, if it is for a short

period . I f this is repeated, however, the future of the

company inevitably becomes unclear.

I am aiming to create an organization in which employees

work vigorously and which customers and other stakeholders

believe does good work. In order to do so, we have not

judged the situations we face in the way we prefer, based on

easily available data, and we have avoided considering

matters from a short-term perspective. We determine whether

"what we intend to do now" is in accordance with common

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social values, and is correct from a long-term perspective, by

being critical about those of our ideas and operations in

which we have been confident. That is, we see and consider

s i tuat ions not only as business persons but a lso as

individuals viewing situations with our own eyes. Having both

these points of view is important for our organization.

We have now reformed our philosophy which consists of

3parts - mission,vision,way, i.e. the social significance of

our existence, shared by each company in our Group, for

the first time since the start of the Group management

system 10 years ago. Based on the above thinking, we

restated the philosophy in plain terms. At the same time,

the philosophy of each business company in the Group was

made consistent with the Group philosophy. The new

group mission is "Sensitize the people of the world to

beauty". In order to achieve it, 5 action guidelines are set.

The POLA ORBIS Group is characterized in that the Group

is naturally close to our customers because we have carried Satoshi Suzuki

February 15, 2015POLA ORBIS Holdings Inc.Representative Director and CEO

out sales directly to customers since our origin. Taking

advantage of this characteristic, we would like to provide our

customers with special experiences through our employees,

brands, products , and services . This philosophy was

created in accordance with ou r view of people , that

everyone seeks stimuli in their daily lives and wants to have

experiences leading to self-growth. We believe that the

achievement of this philosophy will bring about our long term

continuous growth. Making the celebration of our 100th

anniversary in 2029 one of our goals, we have started to

dynamically move forward as a Group based on this new

philosophy.

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POLA ORBIS Group Philosophy

MAX

Sensitize the world to beauty.

POLA ORBIS Group Mission

Mission

Approach life with boundless curiosity and

fi ll i t with hea r twarming encounte rs and

new discoveries. Make the world different

tomorrow. Inspire a sensit ivit y to beauty

that changes people's lives, making them

feel happier and more emotionally fulfilled.

Corporate Image we Aim for

Vision

Sense of Values / Action Guidelines

Way

To maximize the unique character of each brand,

a n d b e come a g l o b a l c o r p o ra te g ro u p t h a t

enriches the lives of people around the world.

Be gracious to others, and express your individuality with flair.

●

Cultivate your aesthetic sense and personal tastes.

●

Show care for the environment in all that you do.●

Think independently and work cooperatively to grow as individuals and as a group.

●

Respond to challenges and changing circumstances with flexibility.

●

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Sustainability Statement

We, the POLA ORBIS Group, offer enriched lives to people all over the world,

with our supple minds in which rich sensitivity and individuality is woven.

In order to do so, we hereby declare that we will deal with all our stakeholders

and global/social environments in good faith and continue to grow as a

company which helps create a sustainable society.

Human Rights Principle 1. Businesses should support and respect the protection of internationally proclaimed human rights

Principle 2. make sure that they are not complicit in human rights abuses.

Environment Principle 7. Businesses should support a precautionary approach to environmental challenges;

Principle 8. undertake initiatives to promote greater environmental responsibility; and

Principle 9. encourage the development and diffusion of environmentally friendly technologies.

Anti-Corruption Principle 10. working against corruption in all its forms, including extortion and bribery

Labour Principle 3. Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;

Principle 4. the elimination of all forms of forced and compulsory labour;

Principle 5. the effective abolition of child labour; and

Principle 6. the elimination of discrimination in respect of employment and occupation.

In order to offer enriched lives to people all over the world, we, the POLA ORBIS Group, support the "UN Global Compact".

This is a voluntary initiative proposed by the UN to companies, consisting of the following 10 principles concerning human

rights, labour standards, environment, and prevention of corruption.

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POLA ORBIS Group Code of Conduct

ⅰ. PurposeThe p u r p o se o f t h e " PO L A ORB I S G ro u p Cod e o f

fo edoC eht" sa ot derrefer retfaniereh（ "tcudnoC

Conduct"） is to set forth standards for actions to realize

the Group philosophy and for action standards to ensure

processes it not only complies with laws and regulations

of count r ies whe re we a re conduct ing business and

internal regulations but also severely controls itself to

uphold high ethical values of society.

ⅱ. Definitions and Applicable ScopeIn this Code of Conduct, the term "POLA ORBIS Group"

means companies subject to the consolidated accounting,

the term "Group Companies" means individual companies

in the POLA ORBIS Group, and the term "We" mean all

the officers and employees of the POLA ORBIS Group.

The Code of Conduct appl ies to a l l the officers and

gnidulcni（ puorG SIBRO ALOP eht fo seeyolpme

part-time employees, POLA Beauty Directors, temporary

staff working for Group Companies, and regular/irregular

employees dispatched from subcontracted companies）.

We also request our business partners to understand and

comply with the Code of Conduct.

ⅲ. Points of Attention in Utilizing Code of ConductWhen the internal rules, etc. infringe or conflict with the

Code of Conduct, laws, regulations, or external standards

s u ch a s a g re emen t s w i t h i n t h e i n d u s t r y , l aws a nd

r e g u l a t i o n s a n d e x t e r n a l s t a n d a r d s s h a l l t a k e

p recedence , fo l l owed by t he Code o f Conduc t and

internal rules in this order.

When the implementation of any provision of the Code of

Conduct violates local laws and regulations or social

ethics, response judged to be legal and proper through

fair and reasonable consideration together with related

parties (such as an attorney) shall be made.

To the extent of any inconsistency,local policies on the

same subject matter as this Code of Conduct will prevail

where required by local law.

Persons who violate the Code of Conduct and the persons

who ignore violations of the Code of Conduct are punished

in accordance with the Working Rules and other rules.

ⅳ. Responsibilities of ManagementThe directors, auditors, executive officers, and other managers aim

to realize the philosophy by exerting individual sensibility overflowing

with originality and acting as charming individuals based on the

"POLA ORBIS Group Officers Competency", which are the

behavioral characteristics required of the personnel responsible for

managing the POLA ORBIS Group. In addition, the management

understands that the realization of the spirit of the POLA ORBIS

Group Code of Conduct is a task of the management, which takes

the initiative in this realization by setting a good example. Further,

the management establishes an effective internal system, enforces

thorough adherence to the Code of Conduct within the company,

and makes it known to business partners, etc. In case of violation of

law or regulation or any situation violating the Code of Conduct, the

top management works to solve the issue, investigates causes

thereof, promptly takes corrective measures to prevent recurrence,

and takes harsh disciplinary actions as necessary against all

employees concerned including the top management themselves.

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I. Actions to Sensitize the World to Beauty

The POLA ORBIS Group further enhances the sensitivity

which enriches lives , helps people become aware that

t he i r l ives a re fu l l o f beau t y and de l ight fu lness , and

causes the lives of all the people with some connection to

the POLA ORBIS Group to be deepened and widened. In

order to do so, the officers and employees of the POLA

ORBIS Group always ask themselves whether an action

se r ves to rea l ize the g roup ph i losophy, and act a f te r

sensitizing themselves to beauty.

1.Emphasis on Attractive Personality Full of SensitivityEach of us thinks independently as a member of the

POLA ORBIS Group so that people around the world

can spend brilliant daily lives overflowing with smiles

and moving emotion.

①We with our "keen sensitivity" act so that "we and other people

through relationships with the POLA ORBIS Group.②As members of the POLA ORB IS G roup, we recognize the

continue to cultivate attractive individuality.③We improve our individual specialized expertise and creativity while respecting and cooperating with each other, and take up challenges to rea l ize pe rsonal g rowth and new va lues fo r customers and local communities.

2.Creation of Values Desired by CustomersWe th in k on beha l f o f ou r cus tome rs , and p rov ide

science-based unique products and services which will

always be cherished and relied upon by customers.

①We offer customers ways to "make their lives more joyful and richer" based on original and fascinating ideas born from "keen sensitivity".

②We continue to develop innovative technologies and services, and with them try to make "impressions" exceeding customers' expectations.

③ Individual encounte rs with customers a re impor tant to us , because we then can find the beauty in their inner selves and in their ways of living which are their "cores", and promptly present them with suitable ways to display this beauty.

④Each of us seek out and value honest　communications with customers as professionals.

3.Development of Local Communities by Utilization of "Beauty Creating Power"We utilize the "Beauty Creating Power", which is our

strength, at the maximum for our business activities and

the development of the local communities which are the

local infrastructure of people.

①We establish close relationships with local communities, and contribute to the creation of local employment and enrichment of the culture of daily lives through our business activities.

②We verify how we can make our products and services better m e e t t h e d e s i r e s o f t h e l o c a l s o c i e t y t h r o u g h d i a l o g s （conversations） with stakeholders such as customers, clients, local residents, shareholders, and investors, and make every effort to reward the trust placed in us by local communities.

③We transmit the beauty of craf tsmen , t raditional skills , and fo rma t ive a r t s t ha t have been handed down f rom ea r l i e r generations in the local communities , by adding innovative values to them and promoting them to the world.

4.Consideration for Beautiful Global EnvironmentWe continue to cherish and protect the global environment

surrounding us which fosters our sense of beauty and

enriches our sensitivity.

①With our highly developed sense of beauty, we care for the environment out of respect for the irreplaceable benefits we receive from nature and respect for ourselves, one part of nature.

②We understand that our bodies and the environment are closely connected with each other, and when there is a possibility of adverse influence on the environment, we eliminate the threat and improve the situation while maintaining the comfortable usability and the unmistakable effectiveness of our products. Since our activities give beauty to humans, we make every effort to reduce envi ronmenta l bu rdens , and develop and u t i l ize environmental technologies where possible in our processes in o rder to maintain the beauty of natu re , and allow the nex t generation to inherit an attractive global environment.

（1）Activities to Allow the Next Generation to Inherit an

Attractive Global Environment

①With our rich sensitivity and considerateness, we make every effor t to consider the environment f rom the product design stage throughout the product lifecycle, based on our original eco-standards. We protect the environment as citizens of the beautiful earth by working to preserve natural ecosystems e.g. in ou r use of raw mate r ia ls , by des ign ing p roducts , t he i r containers, and their disposal processes that use few resources a nd a re easy to re u se a nd re cyc le , awa re o f impend ing exhaustion of resources.

（2）Provision of Environmentally Friendly Products and

Services

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Actions to Grow as Individuals and Group

The POLA ORBIS Group is strongly aware of its corporate

social responsibilities, and gives priority to fair corporate

activities from the viewpoint of stakeholders , not to the

profits from the viewpoint of our companies. Officers and

employees of the POLA ORBIS Group always ask themselves

whether an action will allow them to continue to be proud

and self- respecting to be employees of the POLA ORBIS

Group in business activities, and, in order to build rich lives

together with customers and stakeholders, we comply with

the following Code of Conduct.

1.Securing of Quality and SafetyIt is precisely because we always take up the challenge

to realize brands and business activities overflowing

with individuality that have not been seen previously in

the industry, that we thoroughly secure the quality and

s a fe t y a l l ow ing cu s tome r s to c on fi den t l y u se o u r

products.

①We make eve r y effo r t to re spond to cus tome r needs and p rovide advanced p roducts and se rvices having excellent effectiveness, safety, fashionableness, and usability.

②When the slightest unfavorable impression is given by products or services provided by the POLA ORBIS Group, we promptly a c t i n good fa i t h to p reven t d amage f r om s p read ing , to invest igate causes the reof, and to p revent accidents f rom reoccurring. Further, if any problem is found, we immediately improve the p roblem th rough cooperat ion between the top management and relevant divisions.

2.Respect of Individual SensibilityWe will develop a work environment which welcomes

opinions of employees, they being charming individuals

with a keen sense of beauty.

①We consider that the respect of human rights means not only the protection of individual rights but also the utilization of t h e i r s e n s i b i l i t i e s . We u n d e r s t a n d t h e mea n i n g o f t h e international standards of human rights, prohibit infringement of human rights in business activities , and make every effort such that we do not indirectly assist such infringement.

②We respect the bount i fu l pe rsona l i t y and p r ivacy of each individual , do not carry out unjust discriminatory t reatment （based on nationalities, races, skin colors, beliefs, sexuality, gende r i d en t i t y , s exua l o r i e n t a t i o n , a ge , s oc ia l o r ig i n s , handicaps, or diseases） or harassment, and prevent the same from occurring.

③We make eve r y effo r t to a lways ma in ta in a hea l t hy wo rk environment, prevent and eliminate any and all harassment in workplaces including sexual harassment, power harassment, mo ra l h a r a s smen t a n d ma te r n i t y h a r a s smen t , a n d t a ke necessary employment management measures.

（1）Respect of Human Rights

①We cooperate with the Labor Union or the representatives of workplaces, maintain a fair and healthy relationship with the Labor Union, and cooperate with each other.

〈3〉 Cooperation with Labor Union, etc.

①We thoroughly manage safety and health in order to eliminate labor accidents, to prevent diseases, and to promote health . Further, we make every effort to promote our own health and secu re ou r sa fet y, and a t the same t ime , we endeavo r to maintain and improve a favorable working environment while paying attention to the health and safety of surrounding persons.

②We do not drink alcohol in workplaces during working hours,with the exception of officially sanctioned workplace events.

〈2〉 Realization of Safety and Health

①We endeavor to establish a workplace culture where people having various backgrounds can fully exploit their personal talents, where opportunities for challenges are provided, and where lively communication is carried out.

②We consider a good work-life balance to be important, and try to develop a work environment where employees can devote their whole energy to their duties.

（2）Securing of Safe Work Environment where Employees 　 can fully demonstrate one's ability

Individuality

3.Corporate Management Using Messages with its own Sensibility and WordsWe earnestly face truths in front of us and maintain our

cu r ios i t y about unknown mat te rs , thus making new

encounters and discoveries. These fulfill not only the

requests from society but also our own insistent desires,

and we offer them to society.

①We act with corporate governance as our basic policy. This stipulates that we accept diversity deriving from independent action of individuals , thus acquiring and exhibiting the same fl e x i b i l i t y a s g r ow i n g p e r s o n s , a n d t h a t w e m a ke o u r management judgments transparent. We try to achieve further development in order to realize improvement of corporate value.

②We clea rly communicate ou r philosophy, ea rnest ly accept opinions and criticisms regarding them, and try to obtain the trust of people in Japan and overseas.

③We ma ke eve r y e ff o r t t o p r omo te u n d e r s t a n d i n g o f o u r management and business activit ies by timely and properly disclosing information to our shareholders.

④We actively disclose financial info rmation and nonfinancial information as appropriate based on the Disclosure Policy to society in o rder to deepen the understanding of the POLA ORBIS Group.

（1）Improvement of Transparency of Management

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①We comp ly w i t h l aws , r egu la t i o n s , a n d s o c ia l e t h i c s i n marketing activit ies such as displays , adver t isements , and publicity, whose contents and expressions are fair, without fa l s e c la ims o r exagge ra t i o n s , s oc ia l d i s c r im ina t i o n , o r infringement of human rights.

②We do not exh ib i t d is respect f u l o r s lande rous messages concerning competitors.

（2）Proper Displays, Advertisement, and Publicity

①We comply with accounting principles and accounting practices which a re conside red to be fa i r and reasonable , and with related accounting laws such as the Commercial Law and the C o r p o r a t e L aw . F u r t h e r , we c o r r e c t l y ke e p b o o k s a n d accounting records , and do not fa lsely o r ficti t iously enter records.

②We continuously properly evaluate whether the internal control system for financial reports is in place and operating effectively. Fu r t he r, we fu l ly coope ra te in inves t iga t ions conce rn ing financia l info rmation , including accounting audits and tax investigations by the government, internal auditors , external auditors, and persons in charge of internal investigations.

（3）Securing of Trust in our Financial Reports

4.Continuously Taking up New Challenges Together with ClientsWe always take up new challenges to create unprecedented

va lues in coope ra t ion with ou r c l ients , and a lways

promote fair and free competition.

①In cooperation with our business partners , we use our power for innovation to improve both our and their corporate value.

（1）Creation of New Values

①Under no circumstances do we perform any act constituting a violation of the Antimonopoly Act , such as car tel formation , co llus ion , resa le p r ice maintenance , o r abuse of supe r io r b a rga i n i n g p os i t i o n , a n d fa i r l y a n d f r e e ly c ompete w i t h competitors

（2）Prohibition of Anti-Competitive Practices

①We comply with laws and regulations, rules, internal regulations and standards in relat ionships with business pa r tne rs such as purchasers, suppliers, and business/manufacturing subcontractors, and with officials of relevant government offices. In addition, giving and receiving gifts and entertainment is prohibited in principle.

（3）Prohibition of Bribery

①We have absolutely no connection with anti-social forces and entities which threaten public order and safety.

（4）Prohibition of Involvement in Anti-social Forces

①When making po l i t ica l dona t ions o r dona t ions to va r ious associat ions , we obtain p rio r approval in accordance with internal regulations, and properly make the donations.

②We strictly refrain from performing activities which may cause the misunderstanding that we have unofficial relationships with political or administrative organizations, such as donations of money or goods and making facilitation payments, and we make every effort to establish healthy and transparent relationships.

（5）Healthy Relationships with Political and 　 Administrative Organizations

① We carry out proper procedures in accordance with applicable laws and regulations concerning commodity distribution, export and import. We do not export or import goods whose import or export is prohibited.

（6）Proper Export and Import Management

①We make every effort to realize healthy, proper, and fair business practices in cooperation with our business partners such as suppliers and subcontractors.

②We make eve r y effo r t to rea l ize sus ta inab le raw mate r ia l procurement which does not encourage illegal acts or environmental destruction, in cooperation with our business partners.

（7）Responsible Procurement / Purchase

②We strive to always act conscientiously, with basic awareness of laws, social propriety, and justice, so that we do not get involved in illegal or antisocial acts.

③We ta ke sufficien t ca re not to p rov ide p ro fi t s to c r im ina l organizations or operations, and we have absolutely no involvement with illegal money laundering.

5.Further Utilization of New Values as AssetsThe purpose of the intellectual properties of the POLA

ORBIS Group is to contribute to the development of

society. We strictly manage them as assets that must

be protected while utilizing them as a way of activating

the Group's participating market.

①We also respect intellectual property rights of other companies, and we do not perform any activity which infringes such rights. In addition , we try to prevent disputes by fully investigating beforehand whether a proposed operation infringes intellectual proper ty rights of other companies . Fur ther, in cooperation with other companies, we make wide ranging contributions to

〈2〉 Handling of Intellectual Properties of Other Companies

①We recognize that results obtained in the course of business such as research and development (such as patents , utility models , designs , t rademarks , copyrighted works , know-how, and technica l in fo rmat ion) a re impo r tant company assets ( intellectual proper ties) , and use them widely as means for en riching societ y. We duly reco rd and manage the above results, and try to obtain IP rights. When results fall within the scope of our business, these are reported without delay and handled properly and promptly.

（1）Protection and Utilization of Intellectual Properties〈1〉 Protection of Intellectual Properties Belonging to the 　　POLA ORBIS Group

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①We efficiently utilize company assets, properly manage tangible ,secived ,seitilicaf sa hcus（ stessa ynapmoc elbignatni dna

equipment, commodities , sof tware, information, and working hours of employees）, and use these only for business purposes. Further, we properly handle these assets, tangible or intangible, so as to prevent damage and theft.

（2）Protection of Company's Assets

①We strictly manage trade secrets of our company and other companies in the trade secret management, do not divulge the same outside of the company, and do not use the same for any other purpose than business purposes and purposes permitted by the other companies.

②When disclosu re of confidentia l info rmation outside of the company, e.g. to business partners, is required, we endeavor to prevent unexpected information leakage by e.g. choosing reliable partners and concluding a confidentiality agreement.

③We do not obta in , f rom a th i rd pa r t y, info rmat ion which is suspected to be confidential information of a party other than that third party.

④We properly and strictly manage all the personal information obtained in the course of business. Further, we do not disclose the same to any outside third par ty without carrying out the proper procedures.

（3）Strict Management of Confidential Information

①We understand that the public evaluation of the POLA ORBIS Group and its brand image depend on the behavior of each Group employee, and we endeavor to act ethically and use proper language.

②When convey ing in fo rmat ion as an ind iv idua l , we c lea r ly distinguish public matters and private matters so that official information issued by the company and information conveyed between individuals are not mixed with each other.

③We understand that information posted on the Internet cannot be completely deleted. In particular, when using social media, we note that t ransmit ted information is broadly spread in a sho r t t ime , a nd we t ra nsmi t i n fo rma t io n knowing we a re responsible for the consequences.

（1）Individual Assertions that Improve Brand Values

6.Actions Full of Brand PrideWe understand the value of the POLA ORBIS Group

brand, understand that our individual behavior influences

the image that our brand evokes, and act with pride as

the employees of the POLA ORBIS Group.

①If we come to learn inside information of Group Companies , business partners , or competitors in the course of business, we do not sell or purchase shares/corporate bonds of such companies and we do not otherwise use the information for personal purposes until the information is officially published. When purchasing o r selling shares of G roup Companies o r companies with which there are business relationships , we confirm in advance whether we have any inside information.

（3）Prohibition of Insider Trading

①We perform political activities as individuals , and do not use working hours and company's facilities and assets for political activities.

（4）Political Activity

①We t ry to p revent our personal inte rest and the company's interest from conflicting with each other. Before taking actions which may cause confl icts of in te res t , such as s ide jobs , emp loyment o f c lo se re la t i ves and fami ly membe rs , a nd t ransactions with close relatives , we obtain , as necessary, permission from the company.

（2）Avoidance of Conflict of Interest

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Supplementary Provisions

1.Effective Date

2.Revision and Abolition of Code of ConductRevision or abolition of the Code of Conduct shall be approved at a Group Strategy Meeting.

3.Contact Desk.）6255-3653-3-18：leT（ eettimmoC RSC puorG eht fo ecffiO evitartsinimdA eht eb llahs tcudnoC fo edoC eht fo ksed tcatnoc ehT

This POLA ORBIS Group Code of Conduct was established on August 24, 2007.

This POLA ORBIS Group Code of Conduct was implemented on October 1, 2007.

This POLA ORBIS Group Code of Conduct was partially revised and implemented on January 1, 2009.

This POLA ORBIS Group Code of Conduct was partially revised and implemented on February 14, 2017.

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Check Column

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In personCheck

DivisionHead

Confirmation

Employee Number Full name

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