ITO EN, LTD.

ITO EN aims to be recognized as a corporate Group that upholds the highest compliance standards, through adherence to all laws and sound corporate ethics by every employee.

Overview of Compliance Philosophy

ITO EN aims to ensure that all corporate management and business operations are conducted in full compliance with laws and regulations and in an appropriate manner. We treat the trust placed in us by consumers, shareholders, local communities and other stakeholders with the utmost respect, and our fundamental compliance philosophy is based on our sincere commitment to honoring the trust and expectations of all stakeholders. Accordingly, we strive to maintain a thorough level of compliance with laws and internal.

Compliance System

In 2004, we established the Compliance Committee as an advisory body to the Board of Directors. The Compliance Committee submits the results of its deliberations to the Board of Directors. Also in 2004, we established the Compliance Department within the Legal Department. The Compliance Department reports any compliance matters identified through an internal whistleblower system and other means to the Compliance Committee, and also liaises with outside legal counsel where necessary to deal with compliance matters. In May 2007, the Compliance Department became an independent department and staff numbers were increased to reinforce the Company's compliance system.

Measures to Reinforce Compliance

ITO EN aims to be recognized as a Group that sets and maintains extremely high compliance standards. In accordance with this aim, we focus considerable efforts on compliance training to raise the level of compliance awareness among employees of ITO EN and all Group companies.
　　　　We have established a corporate ethics hotline to ensure the effectiveness of our internal whistleblower system. The ITO EN business diary carried by all employees contains the ITO EN Group mission statement, Code of Conduct, conduct checklist, conduct handbook, and conduct standards Q&A.

ITO EN Group Corporate Code of Conduct

1. We provide natural, healthy, safe, well-designed and delicious products to customers based on excellent technologies.
2. We conduct all business dealings in an equitable and fair manner.
3. We provide timely and appropriate disclosure to improve stakeholder understanding and evaluation.
4. We aim to continuously raise corporate value and strive to create an attractive company.
5. We respect basic human rights and strive to maintain a positive working environment.
6. We deal proactively with environmental issues.
7. We comply with laws, regulations and company ethics rules, and work to build sound relationships with the community as a responsible corporate citizen.
8. We, as individual ITO EN Group employees, strive to contribute to the development of local communities and make a positive contribution to international society.
9. We make the utmost effort collectively to win customer peace of mind, satisfaction and trust.

Corporate Ethics Hotline (Whistleblower System)

We have established a corporate ethics hotline as a channel for receiving internal whistleblower reports, consultations, questions, and as a general point of contact for compliance and ethics issues. This is part of our system to ensure that compliance violations and fraudulent activities are dealt with rapidly and appropriately. The hotline comprises the Compliance Department and outside attorneys, and may be contacted though meetings, telephone calls, letter, fax or email. Whistleblowers are protected under internal whistleblower rules in accordance with the Whistleblower Protection Law. All reports are investigated thoroughly, and the results are reported to the original whistleblower and the Compliance Committee. These measures help to prevent the recurrence of similar problems in the future.

Personal Information Protection (Privacy)

ITO EN strives to protect customer privacy through strict adherence to the Personal Information Protection Law and other relevant laws and regulations. Personal information is stored, maintained and managed appropriately. Personal information is only collected when appropriate and necessary and is used only for the purpose originally specified. No personal information is disclosed to third parties except in cases stipulated under law. To prevent personal information leaks, all appropriate measures are taken to ensure secure management of information.