Nikon Code of Conduct

• Introduction
• Nikon Code of Conduct
  • 1.Sound corporate activities
  • 2.Provision of valuable goods and services for society
  • 3.Respect for Human Beings
  • 4.Protection of the Natural Environment
  • 5.Responsibility to Society as a Corporate Citizen
  • 6.Transparent Operating Activities
  • 7.Responsibility of Top Management
• Closing

Introduction

1. What is the Nikon Code of Conduct?

   The Nikon Code of Conduct sets the standards of behavior for Company directors and employees. By following the code, we conduct activities in compliance with all applicable laws and other standards of ethical conduct to practice the Nikon Corporate Social Responsibility (CSR) Charter.
   While the Nikon Corporate Social Responsibility (CSR) Charter describes Nikon's basic policy on social responsibility, implementation of the Nikon Code of Conduct by everyone will help to promote our social responsibilities.

2. Scope

   The Nikon Code of Conduct applies to all directors and employees of Nikon, as described below. "Nikon" as mentioned herein refers to Nikon Corporation and both its domestic and international subsidiaries, and "we" refers to all directors and employees of Nikon. Other affiliate companies are recommended to apply the Nikon Code of Conduct itself or its contents.

Nikon Code of Conduct

1.Sound corporate activities

1. Compliance
   1. We will make every effort to understand and comply with corporate rules, and applicable laws and regulations, governing the conduct of our business in various countries.
   2. We constantly endeavor to understand applicable laws related to our business and, when necessary, consult with relevant corporate departments, specialists, administrative authorities, etc.
2. Integrity
   1. We will make every effort to comply with applicable rules, operate in a sincere appropriate manner, and strengthen our corporate competencies.
   2. We try to control and manage company assets including facilities, equipment, funds, information, intellectual, properties and software appropriately to prevent misplacement, theft, damage, etc. We will not use company assets for private or fraudulent purposes.
   3. We will not engage in any activities that damage Nikon's reputation or financial interests in order to benefit ourselves or third parties.
   4. We cooperate in maintaining social order, and will not engage in antisocial, disruptive activities.
3. Fair Competitions and Transactions
   1. Based on the principle of fair and open competition, we promote competing vigorously in the marketplace, but it is our policy to do so by fully complying with all antitrust and other competition laws of governments in applicable countries.
   2. We may not enter directly or indirectly into any formal or informal agreement with competitors that fixes prices, allocates markets, eliminates competition, or otherwise unreasonably restrains trade.
   3. We exchange legitimate contracts with our customers, suppliers, etc., and adhere to those contracts.
4. Appropriate Purchasing/Procurement with Suppliers
   1. We select our suppliers appropriately and fairly. We base our supplier relationships on lawful, efficient and fair practices.
   2. We will not exploit our position in business relationships to force onto our suppliers certain unethical conditions or disadvantages, engage in fraudulent activities, or seek personal gain.
   3. We also expect our suppliers to adhere to compliance, business ethics, product quality and safety, human rights protection, fair labor practices, health and safety, environmental preservation, information security, etc., and promote socially responsible behavior within our supply chains.
5. Information Management
   1. We manage business information including personal information appropriately in accordance with their degree of confidentiality to avoid loss and unauthorized disclosure.
   2. We take every reasonable precaution to keep confidential information confidential. The obligation to protect our confidential information continues even after employment terminates. We will not use such information for our own purposes.
   3. We obtain personal information only for legitimate business needs. We will not use obtained personal information for any other purpose other than as originally specified.
6. Protection of Intellectual Property Rights
   1. We respect the intellectual property rights of third parties. We obtain intellectual property information from third parties using legitimate and appropriate methods. We consult with specialist or other designated section concerning necessary licenses or approvals to use such intellectual property.
   2. We cooperate in establishing, protecting and utilizing corporate rights in all Nikon intellectual property assets.
7. Export Control
   1. We conduct international transactions which are subject to export control laws and regulations.
   2. We need to know, understand and comply with related export control laws and regulations, as well as corporate rules, upon export of hardware (such as products and components), and upon transfer of technical information controlled by export regulations.
8. Insider Trading Prevention

   We will not engage in insider trading of securities based on confidential information not available to the general public.

9. Entertainment and Gifts
   1. We comply with related laws and regulations regarding provision/receipt of entertainment and gifts to/from our customers, suppliers, etc., and engage in such practice to the extent necessary and reasonable under social norms.
      We will not provide or receive entertainment and gifts within the Nikon group.
   2. We will not provide entertainment and gifts to a supplier, vendor, customer, or any other person in exchange for assistance or influence, or upon the understanding that such assistance or influence has been or will be rendered, in connection with any business transaction affecting the company. Similarly, we will not accept entertainment and gifts from suppliers, vendors, customers or other persons under circumstances which may be interpreted as potentially influencing a decision involving a business transaction.
   3. We will report to our superiors on all provision/receipt of entertainment and gifts, except for gifts of nominal value that are normal and customary given the business circumstances.
10. Relationships with public authorities
    1. We are committed

       to maintain sound and sincere relationships with domestic and international public authorities and public service personnel,
       to comply with related laws and regulations, and
       to strive to avoid corruption. Should the possibility of violation of related laws or regulations arise, we will immediately report the situation to our superiors and take appropriate measures.

    2. We take every care to avoid behavior that might raise suspicions of bribery.

2.Provision of valuable goods and services for society

1. Understanding Expectations and Demands
   1. We contribute to society by actively communicating with our stakeholders to understand their expectations and demands, and by providing to society useful products and services reflecting such expectations and demands.
   2. We try to respond to inquiries and requests fairly and promptly. We are committed to providing useful and accurate information in an easy-to-understand form to stakeholders to enable them to make sound decisions and judgments.
2. Safety and Security
   1. We take the utmost care in the quality and safety of our products and services.
   2. We provide user-friendly instructions and other information so that our products and services may be used safely. Should safety issues arise, we will follow prescribed rules to promptly implement appropriate measures such as product recalls, and simultaneously make efforts to prevent recurrence.

3.Respect for Human Beings

1. Respect for Human Rights
   1. We are dedicated to equal employment opportunity. We are committed to compliance with applicable employment laws everywhere we operate, including applicable international human rights laws and regulations. We do not tolerate unlawful harassment and discrimination, but respect the unique individuality of each and every person.
   2. We will not engage in any forced labor or child labor and request our suppliers to follow suit.
2. Comfortable and Safe Working Environment
   1. We mutually accept different opinions and values, provided they do not unlawfully infringe on the rights of others, and work together as one to create a working environment where we can all perform at our best.
   2. We comply with laws and regulations related to labor as well as health and safety to ensure a comfortable and safe work environment.

4.Protection of the Natural Environment

1. We conduct environment-oriented business operations, and work to increase environmental awareness in order to contribute to a sustainable society.
2. We strive to reduce environmental burdens in all stages of our business operations—from procurement of raw materials to development, manufacturing, logistics, sales, use, services, and finally disposal—and provide environmentally friendly products and services.
3. We not only comply with environmental laws and regulations, but also actively strive for appropriate use and management of chemical substances, waste reduction, etc. We also make assertive efforts to reduce CO₂ emissions, such as implementing energy-efficient facilities and energy conservation.
4. We strive for resource conservation, efficient use, re-use and recycling so as to realize sustainable use of limited resources.

5.Responsibility to Society as a Corporate Citizen

1. As members of Nikon, we try to understand and respect the cultures and customs of each country and region in which we do business.
2. We understand and actively cooperate with Nikon's basic philosophy on social contribution activities.

6.Transparent Operating Activities

1. We promote fair and open communication with our stakeholders. We try to disclose useful and proper information in a timely manner to further the interests of the parties.
2. We follow appropriate accounting practices based on facts to realize timely and proper information disclosure. We will not engage in inappropriate accounting practices to secure profits, achieve sales budgets, fulfill budgeted expenses, or for any other reason.

7.Responsibility of Top Management

1. Executives and organization supervisors will take the initiative in complying with this Code, and strive for thorough compliance with this Code, within its pertinent organizations.
2. Executives and organization supervisors will operate pertinent organizations objectively and fairly, and actively promote communication among its members.
3. Should violations or potential violations of this Code be reported to the company, executives and the organization supervisors will immediately investigate the facts, resolve, as appropriate, and take measures to prevent recurrence.

Closing

1. Consequences of Violation

   Violation of the Nikon Code of Conduct may result in disciplinary actions by the company, up to and including termination of employment and/or in proceedings by government authorities, etc.

2. Reporting/Consulting System

   If you become aware of a violation or a potential violation of the Nikon Code of Conduct, please report it immediately to or consult with your immediate superior. When reporting to or consulting with your superior is difficult, please report to the Reporting/Consulting Office or designated section/person of your company.

   Personal information of the reporting or consulting individual will be managed appropriately, and the individual will receive neither disadvantageous treatment nor retaliation because of the reporting or consulting.

3. Establishment, Revision, Discontinuance

   Establishment, revision and discontinuance of the Nikon Code of Conduct shall take place first with a proposition from the chair of the Business Conduct Committee, next an application to the Executive Committee of Nikon Corporation, and then a final decision. Minor changes will be decided by the Business Conduct Committee chair.