Compliance Guidelines

These Compliance Conduct Guidelines (“Guidelines”) set forth the fundamental principles of corporate ethics and compliance to be observed by all Daikin Group companies and each of their officers and employees in the course of the Daikin Group’s global corporate activities.

1. Providing Safe, High Quality Products and Services. We shall live up to our customers’ expectations and trust by providing safe, high-quality products and services from our customers’ perspectives. Should a problem involving safety or quality arise, we shall take honest and appropriate action as soon as possible.

2. Fair and Free Competition and Fair Trading. We shall comply with all applicable related laws and ordinances in each country and region in conducting all aspects of our business activities. We shall consistently conduct fair corporate activities in compliance with provisions of laws governing free competition and fair trading.

3. Responsible Procurement Activities. We shall, as part of our corporate responsibility, make efforts to comply with the laws and regulations governing the procurement of products, materials, and parts in each country and region, respect human rights, procure mineral resources appropriately, and protect the environment. Recognizing that all suppliers are our important business partners, we shall engage in open, fair, and impartial transactions.

4. Strict Compliance with Trade Control Laws and Policies. We shall comply with trade-related laws and ordinances of each country and region, as well as our Group’s policies relating to security and trade controls.

5. Respect for and Protection of Intellectual Property Rights. Recognizing that our intellectual property rights are important company assets, we shall strive to protect and maintain them and utilize them effectively. We shall respect and make every effort not to infringe upon the intellectual property rights of other companies.

6. Proper Management and Utilization of Information. We shall properly manage our company’s information, as well as confidential information of other companies obtained from our suppliers and other entities, and the personal information of our customers and employees.

7. Prohibition of Insider Trading. We aim to be an “open company” that is trusted by society and highly transparent.

8. Timely and Appropriate Disclosure of Corporate Information. To maintain the trust of shareholders and investors, we shall not engage in insider trading by using non-public information about the Daikin Group or other companies we come to know through our business operations.

9. Preservation of the Global Environment. We shall comply with all applicable environmental laws and ordinances of each country and region, and implement initiatives designed to preserve the environment throughout our value chain.

10. Ensuring the Safety of Operations. We shall always place our top priority on safety in all operations. We shall comply with the relevant laws and regulations, and commit to creating a safe and secure workplace environment through autonomous and voluntary safety activities.

11. Respect for Human Rights and Compliance with Labor-Related Laws and Ordinances. We shall respect the human rights of each and every employee, understand diverse values, and elevate each employee’s unique talents and strengths into the driving force of our organization. We will not discriminate against or harass any person on the basis of nationality, race, ethnicity, religion, color of skin, age, gender, sexual identity, sexual orientation, disability, and other relevant factors. We shall continue to exchange opinions with our supply chain partners to promote our efforts to respect human rights, and shall contribute to the realization of a society in which human rights are truly respected. We shall thoroughly comply with labor-related laws and ordinances of each country and region.

12. Protection of Company Assets and Avoidance of Conflict of Interest. To carefully protect and effectively utilize our tangible and intangible company assets, we shall ensure their proper management. We shall not engage in any conduct that pursues personal interests alone, or creates a conflict with the company’s interests in the course of performing our business operations.

13. Proper Handling of Accounting Procedures. We shall handle accounting procedures appropriately in compliance with the established accounting standards and tax laws in each country and region.

14. Prevention of Bribery and Other Corrupt Practices. We shall comply with all applicable anti-bribery and anti-corruption laws and ordinances in each country and region. We shall not provide entertainment, gifts of monetary value, or invitations to officials and employees of public organizations if such practices would violate applicable laws and ordinances. When offering or receiving entertainment, gift, or invitation to or from business partners, including suppliers, we shall ensure that such practices remain within justifiable limits and are permitted under applicable laws, ordinances, and commercial customs.

15. A Firm Attitude against Anti-Social Activities. We shall take a firm attitude against anti-social forces, criminal organizations, terrorists, and other groups that threaten the order and safety of civil society.

16. Relationship with Society. Aiming to be a “good corporate citizen” trusted by society, we shall maintain self-awareness, pride, and responsibility in our own conduct and, at the same time, strive to act and communicate honestly and fairly. We shall also conduct ourselves in a modest and appropriate manner, especially recognizing that statements made or content posted on social or other media may adversely affect society or our corporate value. To contribute to the sustainable development of society, we shall strive to address social challenges and engage in social contribution activities, focusing on environmental conservation, education support, and harmonious co-existence with local communities.

17. Compliance with Industry-Specific Law and Ordinances. To maintain and develop our business operations, we shall accurately interpret and comply with applicable laws, ordinances, and regulations of each country and region, as well as relevant industry standards and international codes, related to all of our business activities.