Core principles：

Integrity:We believe in and promote acting honestly in all relations and in strict compliance with all applicable laws.J-peco respects the dignity of every person and cares about others’ wellbeing and safety.

Transparency:Mutual respect,dialogue and transparency are the foundation of our relationships.Relations with the authorities,regulatory entities,and govemment agencies shall be conducted following the principles of cooperation,honesty and openness.

Impartiality and independence:We operate in a free,objective,and autonomous manner and avoid any type of corruption or conflict of interest that may affect our decision making.

Responsibility:We respect the environment and all communities within which we operate.

In essence,at J-PECO,we aim at serving with integrity,independence and impartiality and to exceed the expectations of those who trust in our products and services in a responsible manner.

 

What is the purpose of the Code?

The Code of Ethics is a binding set of rules that define the expectation of behavior and set forth the principles that should guide the conduct of J-PECO and all its Professionals in the performance of their duties and in their commercial and professional relations.

 

Who has to comply with the Code?

All J-PECO Professionals have the duty to know and comply with the Code,regardless of their rank,location or the Group company to which they provide services.Each Professional of J-PECO must expressly undertake to comply with the Code.

 

The rules of conduct

Respecting dignity at the workplace

J-PECO connitment to the values in this Code would not be credible if they were not reflected in an employment relationship based on respecting the dignity of every employee.The employment relationship shall be free from any abuse of authority or any conduct that might seriously offend others.

J-PECO operates in various cultures,with different customs that we have to learn about and respect,acting in a respectful manner and according to the different social norms.

Our Anti-Discrimination Policy is focused on the prevention of any type of discrimination in hiring decisions,professional promotions,workplace organization or disciplinary actions.

 

Preventing health and safety risks and respecting employees’ rights

A healthy work environment and respecting the dignity of employees also includes respecting employees’rights.Our Group will respect the international standards promoted by the International Labour Organization wherever it operates.

The J-PECO Occupational Health and Safety Policies prevent risks and promote Health and Safety in the workplace.

J-PECO has the duty of care and protects the health,safety and welfare of our Professionals and all Professionals have the right to challenge and the authority to stop the work whenever they have concerns about safety.In turn,all Professionals have the obligation to know and comply with the Group’s Health and Safety as well as the safety of all people who might be affected by their activities.

J-PECO recognizes that all persons within our organization have the right to freely affiliate with trade unions.

 

Data protection and privacy

Managing any business today requires the protection of personal data gathered within the scope of employment.Although laws related to data protection vary in the different countries where we operate,J-PECO considers the following elements as fundamental:

※  J-PECO will design Data Protection Policies based on the data protection laws applicable in each country and adapted to each legal framework.

※  In addition to all local laws,all employees or officers must respect these basic rules:

-  With the exception of Human Resources ,the Legal department and the CCO,no officer or employee may access any Professional’s file other than their own unless said access is required to carry out their duties or they are expressly authorized.

-  Personal data may only be collected and filed to the extent necessary in order to achieve a legitimate business purpose,and such information may only be used for the purpose for which it is collected.

-  The personal data of any J-PECO Professional may be accessed during an investigation when there are reasonable grounds to suspect that said Professional has breached the Code,in accordance with applicable laws.

-  Personal data that is processed can only be communicated to third parties in order to comply with obligations directly related to the Company’s activities ,in all cases only with the permission of the person affected.J-PECO may also share personal data in its possession if required by a competent authority.

-  J-PECO and all of its Professionals respect the right to privacy of other Professionals,clients,suppliers and business partners in all its forms.

 

Environmental protection

Our Company will respect all laws related to environmental protection and is committed to sustainability.Therefore we comply with Guidelines for Environmental Best Practices and applicable internal policies and procedures.

 

Market competition and consumers

At J-PECO we believe that innovation and compliance with antitrust and unfair competition laws are the bases for economic growth. Therefore the following are strictly prohibited:

※  Any illegal agreement intended to share markets or to fix prices or bid-rigging in the public or private sector.

※  The improper use and/or disclosure of trade secrets, confidential information or intellectual property rights (such as trademarks,copyrights,and patents) belonging to third parties.

※  The making of any type of any type of offer or advertising that could be misleading or deceitful for clients.

 

Fighting against corruption in J-PECO

J-PECO complies with national and international laws relating to the prevention of corruption in all countries where we are established.

Thus,J-PECO Professionals and Third Parties have the duty to avoid any corrupt practice.J-PECO has implemented a Global Anti-Corruption Policy for all countries where we operate.

This policy prohibits the following activities:

※  To promise or give anything of value to public officials or other companies’ employees to obtain an unjustified treatment or benefit.

※  To give anything of value to public officials or other companies’ employees beyond the specific limits set out in our policy or without observing the Global Anti-Corruption Procedure.

※  To request or accept anything of value from another company to grant an unjustified benefit to said company or a third party.

※  Use a personal relationship with a public official, a member of his/her family or with an official or relevant member of a political party in an improper manner in order to obtain a favourable treatment or unjustified benefit for J-PECO.

※  Pay money to Third Parties acting on behalf of J-PECO without prior confirmation of their professional integrity and their ability to comply with our Anti-Corruption Policy.

※  Make payments to public offcials,other than official tax,duties and fees,even if allowed by local law,to obtain an authorization or to expedite or facilitate an administrative proceeding.

In some countries or geographic areas J-PECO might implement specific Anti-Corruption Policies,which will follow the provisions of the general policy.

 

Veracity of information and record keeping

Guaranteeing the integrity,reliability and accuracy of information is everybody’s responsibility.

 

Confidential and ono-public information

All Professionals of the Group must treat as strictly confidential all reserved information to which they have access as a result of their professional activity in J-PECO.Due to our activity we have access to suppliers and clients’ sensitive information that we must protect and treat confidentially.This includes the obligation not to disclose this information without the consent of the owner of the information.

Any reasonable indication of a leak of confidential information of the personal use of such information must be reported by those with knowledge thereof through the Communication Channel.

Additionally,J-PECO Professionals shall avoid personally benefitting from an opportunity about which they became aware as a result of the access in the course of their work to confidential information.The Information Security Policy specifies these obligations in more detail.

 

Integrity in our services

Our services must be rendered in a professional ,independent and impartial manner ,according to the methods ,procedures ,practices and policies of J-PECO and the laws of each country. Recommendations, professional opinions, data, results and generally any asserted facts must be documented in a careful manner, in compliance with internal policies.

Reports and certifications have to include objective and truthful results and findings, as well as the corresponding opinion of the relevant professionals. J-PECO, in rendering its services, strictly observes and avoids any kind of legal restriction or limitation as the services that it can render.

 

Conflicts of interest

A conflict of interest arises when the personal interest of an J-PECO Professional is, directly or indirectly, in contradiction with the interest of the Group or involves them in a personal manner in any services provided by J-PECO. A personal interest of the Professional shall exist when the matter affects the Professional or a person related thereto.

J-PECO Professionals shall avoid situations that could give rise to a conflict of interest or which could affect their capacity to act or decide impartially and in the best interest of J-PECO.

When faced with a potential conflict of interest: communicate it to your superiors, act with professionalism and loyalty to J-PECO, and refrain from intervening or influencing in the transaction. Further rules on what is considered a conflict of interest and how to act when confronted with one will be found in the internal regulation on conflict of interest.

Common examples of conflicts of interest are:

※  Hiring family members or friends without authorization.

※  Having financial interests in companies competing with J-PECO, or which are clients or suppliers of the Group.

※  Carrying out any paid activity related to the type of services that J-PECO may provide, in addition to work performed in J-PECO.

※  Rendering any other services to J-PECO clients unless duly authorized.

※  Using our employment within J-PECO in order to secure any business or commercial opportunity for ones own benefit.

All of the above conducts may be authorized by your superior in accordance with applicable internal policies.

 

Use of J-PECO resources

As specified in the J-PECO Information Security Policy and related policies, corporate email accounts are the property of the Company and therefore not appropriate for private use. Any use of the corporate email account for private purposes constitutes a waiver of privacy of its content. PCs, laptops, tablets, phones, internet access and other communication systems that J-PECO provides for the use of its Professionals are for professional use and may only be used for personal issues when such use does not interfere with the performance of professional activities. In any case, J-PECO reserves the right to control the use of these means, including communications made in the past, always in compliance with applicable law.

Use of external files and software puts our security at risk and might lead to importanat criminal and civil sanctions for J-PECO. Therefore , any download or use of unauthorized software, any downloads of inappropriate content or any action that violates intellectual property rights is prohibited.

      The rest of J-PECO resources may only be used exclusively for developing our activities and in any case never for personal use. All Professionals must take proper care of resources assigned to them and must avoid damage, theft or any improper use of such resources.