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Cosmo Energy Group Code of Conduct

Chapter 1 We are determined to be a safe, accident-free corporate group

We work to ensure safety and deliver peace of mind in all of our business activities.

1-1. Creating a safe and pleasant workplace environment

1-1-1 Practicing rigorous safety

We all work to prevent accidents by maintaining continual safety awareness at work, even during our commute.

1-1-2 Improving the workplace environment

We strive to keep the workplace safe and clean, while also ensuring that it is tidy and organized.

1-1-3 Practicing rigorous risk management

We work to ensure the safety of employees, their family members, customers and local residents, and to establish systems for rigorous risk management that includes preventative measures and preparedness in case of emergencies including large-scale disasters, terrorism and epidemics.

1-1-4 Ensuring operational efficiency and managing work hours appropriately

We strive to improve operational efficiency and manage working hours appropriately. We also take measures to prevent overwork.

1-1-5 Managing health

We work to promote health care for employees and to maintain and enhance their physical and mental wellbeing.

1-1-6 Practicing health and safety

We do not allow employees to participate in business operations when their safety cannot be ensured due to the influence of alcohol, drugs, illness, etc.

1-2. Preventing accidents and industrial injuries

1-2-1 Practicing rigorous safety management

We always operate and maintain equipment and vehicles properly.

1-2-2 Promoting voluntary safety management activities

We carry out voluntary safety management activities, by independently considering necessary safety measures and taking them.

1-2-3 Communicating with cooperative companies

Our business activities would not be viable without the support of our cooperative companies. We therefore promote good daily communication with relevant people in and outside the company, to further strengthen the safety management system.

1-2-4 Providing safety training

We engage in rigorous education and training to ensure safety. We also strive to improve safety knowledge, technology, and awareness.

1-2-5 Strengthening occupational health management

We assess the workplace environment and take measures to prevent occupational illnesses caused by exposure to hazardous substances.

1-3. Being prepared for accidents and disasters

1-3-1 Ensuring preparedness of disaster prevention systems and equipment

In accordance with the basic spirit of respect for human life, we always have in place systems and equipment to help prevent accidents and disasters, along with emergency response procedures. We also work to improve all these measures.

1-3-2 Maintaining fire-prevention equipment

We provide the management resources necessary to maintain disaster prevention equipment and inspect it regularly.

1-3-3 Improving disaster prevention skills

We regularly conduct emergency drills. Based on the results, we resolve issues and improve effectiveness.

1-4. Responsible handling of accidents and disasters

1-4-1 Responding rapidly and appropriately

We take the necessary measures to minimize damage.

1-4-2 Practicing optimal communication

We communicate (notify, report) rapidly, appropriately and thoroughly with relevant agencies (administrative agencies, related departments in the company, cooperative companies, etc.).

1-4-3 Preventing secondary disasters

We cooperate with relevant organizations and prevent secondary disasters by taking multilateral measures.

Chapter 2 We live up to customer expectations concerning reliability and satisfaction

We develop products and services that meet customer expectations concerning reliability and satisfaction, and deliver them to customers in a stable manner.

2-1. Striving to deliver stable energy supplies

2-1-1 Ensuring stable procurement of resources and raw materials

We conduct stable procurement of resources and raw materials.

2-1-2 Strengthening ties with oil-producing countries

We maintain and strengthen excellent ties with oil-producing countries.

2-1-3 Ensuring a stable supply of products

We operate facilities safely to ensure stable production, delivery, and sale of products.

2-1-4 Planning for business continuity in the event of a disaster

We prepare for disasters through regular training and business continuity planning to facilitate a continued supply of products and services even if a large-scale disaster occurs.

2-2. Providing products and services that customers can rely on

2-2-1 Responding to customers in good faith

We strive to interact with customers in good faith to ensure that they feel comfortable and secure, and gain confidence in our work.
We also strive to ensure that the business partners who handle our products and services understand and respect the spirit of our Code of Conduct and comply with it.

2-2-2 Maintaining quality and securing safety of products and services

We recognize that maintaining the quality and securing the safety of our products and services is fundamental to maintaining trust in the company. We do not provide products or services that do not comply with the stipulated quality and safety standards.

2-2-3 Complying with quality and safety standards around the world

We comply with all standards and regulations relating to product quality and safety, both in and outside Japan.

2-2-4 Totally rejecting illicit gasoline and gas oil

We recognize that the manufacture, sale, or use of adulterated petroleum products undermines public trust and is not acceptable.

2-2-5 Pursuing technological innovation and enhancing expertise and skills

We strive to promote technological innovation and enhance knowledge and ability as a means of developing and providing useful, safe and high-quality products and services, and endeavor to achieve sustainable growth and resolve social issues.

2-3. Striving for customer satisfaction

2-3-1 Appropriately disclosing and explaining product information

We ensure that information is fair and complete so that products and services can be used safely. We also properly label and clearly explain safety information, including warnings about hazardous properties or incorrect use.

2-3-2 Developing and providing products and services that satisfy customers

We accept feedback concerning products and services from customers sincerely, and strive to develop and improve products and services that can satisfy them. We also strive to provide customers with responsible support and after-sales service.

2-3-3 Practicing fair business dealings

We deal fairly with customers by ensuring that we never provide fabricated, falsified or inaccurate data or stipulate unreasonable conditions. We also prohibit improper solicitation methods as well as unjustifiable premiums and misleading representations.

2-3-4 Responding to quality defects and problems

In the event that a product- or service-related defect or problem occurs, we make every effort to make a speedy, appropriate response, placing top priority on ensuring customer safety, averting danger and preventing any damage from spreading.

2-3-5 Identifying causes and preventing recurrence

If any problem arises, we promptly notify the relevant persons, and investigate the causes. We also take measures to prevent it from occurring again.

Chapter 3 We value people

We respect individuals and their fundamental human rights, and strive to create a workplace environment where individual employees can demonstrate their abilities to the full.

3-1. Respecting diversity and each individual

3-1-1 Respecting fundamental human rights

We respect the fundamental human rights of individuals, and neither engage in nor condone actions that infringe on human rights. We support the principles and spirit of the Universal Declaration of Human Rights, which calls, among other things, for respect for the individual, prohibitions on discrimination and slavery, and freedom of thought, conscience, religion and expression as common standards to which all peoples and nations should aspire.

3-1-2 Prohibiting discrimination

We neither discriminate nor condone discrimination on the grounds of birth, nationality, race, beliefs, religion, sex, age, disability or sexual orientation.

3-1-3 Prohibiting forced labor and child labor

We neither force people to work against their wishes, nor condone it. We do not condone child labor, or employ children.

3-1-4 Respecting the lands and rights of indigenous peoples

We support the principles and spirit of the United Nations Declaration on the Rights of Indigenous Peoples, and respect the land and other rights of indigenous peoples.

3-1-5 Taking a careful approach to business in countries with human rights issues

We make decisions on starting and continuing businesses in countries with serious human rights issues after taking into consideration whether we can act in accordance with this Code of Conduct and have a beneficial impact on the countries in question.

3-1-6 Taking security measures with respect for human rights

We support international standards concerning the use of weapons such as the UN's Code of Conduct for Law Enforcement Officials, and do not adopt security measures that infringe on human rights.

3-1-7 Implementing initiatives for human rights due diligence

We value collaboration with stakeholders including local companies, NPOs, NGOs, and government agencies in our business activities, and cooperate with a wide range of stakeholders to support the development of local communities, etc.

3-2. Working to create bright workplaces where employees can work comfortably

3-2-1 Ensuring assessments are fair and equitable and prohibiting discrimination, etc.

In the areas of personnel management, treatment and employment, we make fair and equitable assessments based on aptitude and abilities, and do not discriminate or treat unfairly. We disclose the results of personnel assessments to the persons in question, together with explanations, in an appropriate manner.

3-2-2 Promoting a healthy work/life balance

We respect the values and life philosophies of individual employees and strive to promote their endeavors to achieve harmony between work and life (work-life balance) and realize lifestyles that allow them to lead the lives they aspire to.

3-2-3 Respecting diversity

We respect the individuality of all employees, and strive to create diversity in the workplace to allow them to enhance and demonstrate their abilities. We strive to respond to the need for diversity in work arrangements through such things as part-time and flextime schemes to accommodate child care and nursing care requirements, etc.

3-2-4 Prohibiting harassment

We neither condone nor engage in workplace bullying or any other form of abuse of authority which unreasonably infringes on the individuality or dignity of others or exceeds the bounds of appropriate business leadership. This includes harassment that harms the work environment and/or mental and physical health. We neither condone nor engage in sexual harassment, and refrain from any kind of sexually suggestive behavior.

3-2-5 Ensuring stable employment

We work to support schemes designed to ensure stable employment.

3-2-6 Maintaining healthy employee/management relations

We respect basic labor rights including the right to organize and the right to collective bargaining, and are working to build healthy, transparent employee/management relations.

3-3. Fostering strong human resources

3-3-1 Providing employee education

We endeavor to foster human resources prepared for assignments in and outside Japan by offering programs that help employees reach their full potential.

3-3-2 Ensuring technological continuity

We mentor our successors to ensure that the technology and know-how that we have built up to date through experience and effort are passed on to the next generation of employees.

3-3-3 Practicing self-development

We practice self-development to improve our personal skills and abilities. We continually take on challenges with a positive attitude, while embracing changes in the global community.

Chapter 4 We take care of the global environment

We work faithfully, proactively and continuously on environmental preservation measures and activities.

4-1. Doing what we should to preserve the global environment

4-1-1 Mitigating climate change

We strive to help mitigate climate change by implementing measures to suppress greenhouse gas emissions, reduce energy consumption, and improve energy usage efficiency at all stages of our business activities.

4-1-2 Minimizing environmental impact

We work to reduce pollutants and waste generated from business activities, while properly treating waste, exhaust gases, and wastewater. We also conduct accurate environmental monitoring, and manage emissions accordingly.

4-1-3 Conserving water and marine resources

We recover and efficiently reuse water at our refineries, making every effort to conserve water resources. We also take marine conservation measures in shipping.

4-1-4 Enforcing rigorous soil preservation measures

We implement measures to prevent any soil pollution at our refineries, oil depots and service stations. In the event that soil pollution occurs, we deal with it in an appropriate manner.

4-1-5 Promoting green purchasing

When purchasing materials and services, we carefully consider their impact on the environment, and select those that have the minimum environmental impact.

4-1-6 Practicing environmentally responsible business planning

When planning new businesses, the development and provision of products and services, installations of large facilities, and large-scale construction projects, we consider their environmental impact and adopt whatever preventive measures may be necessary.

4-2. Taking action for the future of the global environment

4-2-1 Practicing environmentally responsible business expansion and technological development

We develop products with a smaller environmental impact, proactively develop technologies for new energy businesses that help preserve the environment, and promote technology transfers relating to energy conservation and environmental protection.

4-2-2 Contributing to environmental education

We engage in educational activities pertaining to environmental issues through proactive involvement in global environmental preservation activities such as efforts to mitigate global warming and support environmental education programs for new generations of children.

Chapter 5 We value communications with society

We actively promote public relations activities, disclose corporate information to foster mutual understanding, and promote the development of local communities.

5-1. Working for the development of the community

5-1-1 Participating in social contribution activities

As a good corporate citizen, we proactively engage in social contribution activities in order to contribute to the realization and sustainable development of a prosperous society. In addition, we respect employees' awareness of volunteer activities and construct support systems for them.

5-1-2 Collaborating and cooperating with local communities

We value collaboration with stakeholders including local companies, NPOs, NGOs, and government agencies in our business activities, and cooperate with a wide range of stakeholders to support the development of local communities, etc.

5-1-3 Respecting the environment, culture and customs of the host country/region

Before engaging in large-scale investment and/or business development, we first assess the impact on the country or region concerned. In addition to complying with applicable laws, regulations and social codes, we respect the local environment, culture, customs, and history, while contributing to local social development.

5-1-4 Developing human resources from the local community

Wherever we are active, be it in or outside Japan, we endeavor to foster local human resources.

5-2. Striving to keep people informed

5-2-1 Engaging in honest publicity activities

We engage in honest, proactive publicity and communications activities to promote better understanding of our business activities, management vision and policies. We also create opportunities and forums for dialogue with a wide range of stakeholders to build relationships of trust by faithfully reflecting the feedback we receive in our business activities.

5-2-2 Disclosing information in a timely and appropriate manner

We disclose in a timely and appropriate manner any corporate information that should be disclosed, including information concerning our financial position, management, environment, safety and any other information concerning societal aspects. We ensure that the content of the information we disclose is accurate, fair and adequate. We do not cover up or falsify information that should be disclosed. In addition, we proactively engage in constructive dialogue with shareholders, investors, etc. to continue improving corporate value.

5-2-3 Using appropriate accounting procedures

We use appropriate accounting procedures and record accounting facts in an appropriate manner and without fail. We do not make false or fictitious entries, hide assets or engage in any other improper accounting procedures or manipulation of accounting information.

5-2-4 Preparing legal documents using appropriate procedures

We prepare accounting documents, financial statements and other legal documents in an appropriate manner.

Chapter 6 We strive to maintain our position as an honest corporate group

We act with honesty as responsible and sensible members of society.

6-1. Engaging in sensible activities as members of society

6-1-1 Enforcing corporate ethics thoroughly

We comply with laws and regulations, in-house regulations and social codes, and act fairly and honestly as members of society.

6-1-2 Acting with constant awareness of responsibility to society

In our individual behavior, we are always aware of and fulfill our responsibilities to society.

6-1-3 Complying with laws and regulations, etc., in daily life

We comply with laws and regulations in our daily lives as well as our business activities. As part of our responsibilities as members of today's automotive society, each one of us raises awareness of traffic safety and drives safely.

6-1-4 Refraining from mentioning business details in public places or online

As individuals, we do not discuss sensitive information concerning the business in public places or on the Internet.

6-1-5 Carrying out thorough training in corporate ethics

We carry out thorough education and training in corporate ethics and take various other steps to keep raising awareness of ethics.

6-1-6 Drawing a clear line between business and private matters

We do not use the company name or the positions or rights we have in the company for activities unrelated to the company's business, or to secure personal or other improper benefits.

6-1-7 Prohibiting insider trading

We do not use confidential internal information concerning the company or business partners for personal gain. We never buy or sell shares of the company or business partner if we are privy to any such confidential internal information (insider trading), unless the information has been officially announced.

6-1-8 Prohibiting conflicts of interest with the company

We do not engage in transactions that compete with the company, hire or supervise immediate family members or close relatives, take actions that impact hiring conditions, or do anything else that conflicts with the company's interests. In addition, we do not assume positions such as director in third-party organizations, except as part of the company's business.

6-2. Managing and using company property properly

6-2-1 Using company property correctly

We use assets, intellectual property, information and other company property appropriately and efficiently. We use company property for business purposes only, not for personal or other improper purposes.

6-2-2 Managing company property properly

We manage company property properly to prevent it from being damaged, lost or stolen.

6-2-3 Properly managing and effectively using intellectual property

We recognize that intellectual property created in business activities is an important company asset, and we make effective and appropriate use of it, while properly preserving and managing the property rights.

6-2-4 Managing and using the Cosmo brand appropriately

The trade name and trademarks including “Cosmo Oil” and the “Oval Mark” are important intellectual properties of the company, and we manage and use them appropriately.

6-2-5 Respecting the intellectual property of others

We respect the intellectual properties of others, and do not engage in acts, such as unauthorized use, that infringe on their rights.

6-2-6 Prohibiting unfair competition

We do not engage in unfair competition using representations that resemble other companies' products or business representations, or wrongfully obtaining the business secrets of others.

6-3. Conducting honest transactions

6-3-1 Sharing prosperity with business partners

In addition to respecting our business partners' positions and promoting mutual prosperity, we confirm that they are following this Code of Conduct.

6-3-2 Promoting responsible procurement

We appropriately select business partners in every stage of business activities in consideration of our company's social responsibilities, and practice honest, fair and impartial transactions and responsible procurement.

6-3-3 Responding to ethical violations by business partners

We take steps to suspend business transactions with business partners if they engage in legal violations that have a major impact on society and fail to rectify the situation.

6-3-4 Providing incentives based on clear criteria

If we offer rebates and incentives to business partners, or impose penalties or disincentives, we do so in accordance with clear criteria.

6-3-5 Conducting fair transactions

We do not use private monopolies, cartels or unfair business practices in transactions. We do not engage in acts such as refusal to accept, payment delays or the imposition of unreasonable terms of business.

6-3-6 Restricting entertainment and gifts

We do not give or receive entertainment or gifts that deviate from social norms or internationally accepted conventions. Moreover, we do not give or receive inappropriate entertainment or gifts for the purpose of providing personal or other improper benefits.

6-3-7 Maintaining healthy relationships with government and administrative agencies

Be it in or outside Japan, we do not entertain or exchange gifts with civil servants or equivalent persons (including former civil servants). We also do not make improper monetary donations, payoffs or benefits to politicians (including political candidates and former politicians) or political organizations.

6-3-8 Prohibiting bribery

We do not engage in bribery, or promise or request bribes.

6-3-9 Avoiding all interaction with organized criminal elements

We have absolutely no relationships with organized criminal elements or groups who may threaten social order or safety, and we do not compromise with them or grant them any benefit whatsoever. We also do not involve ourselves in money laundering.

6-3-10 Following proper import/export procedures

We follow proper customs procedures for exports and imports, including procedures for security export control examination. In the event of economic sanctions on a country with which the company trades, we follow the guidelines of the Japanese government.

6-4. We handle information properly

6-4-1 Acquiring information appropriately

We do not acquire information by improper means, or without the permission of a person with legitimate authority.

6-4-2 Using information appropriately

We use information for business purposes only, not for personal or other improper purposes. In particular, we use personal information (including the personal information of employees), and confidential company information for business purposes only and with the permission of the person(s) in question or the company, as applicable. We do not disclose personal or confidential information without the permission of the person in question or the company, as applicable.

6-4-3 Managing information appropriately

We take appropriate measures to prevent personal or confidential company information from being leaked, destroyed or damaged, and keep it secure through more rigorous management.

6-4-4 Using information systems appropriately

We use the company's information systems in an appropriate manner and in accordance with related rules. We use information systems for business purposes only, not for personal or other improper purposes.

6-4-5 Fulfilling the obligation not to disclose information after retirement

Even after retirement, we do not disclose to third parties personal or confidential information obtained in the course of business during employment without the permission of the person(s) in question or the company, or use such information in ways that go against their wishes.

Established: April 1, 2003 (Cosmo Oil Co., Ltd.)
Revised: January 27, 2004
Revised: January 31, 2006
Revised: May 30, 2006
Revised: August 3, 2007
Revised: January 21, 2008
Revised: October 1, 2008
Revised: September 24, 2014
Established: October 1, 2015
(Cosmo Energy Holdings established.)
Revised: September 28, 2018

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