B A S I C P O L I C Y A G A I N S T A N T I S O C I A L F O R C E S

Based on the Japanese Government’s “Guidelines for How Companies Prevent Damage Caused by Antisocial Forces” (June 2007), MAXIV Co., Ltd. and its group companies (hereinafter referred to as the “Company”) shall cut off all relationships with antisocial forces that threaten public order and safety. In order to maintain sound corporate activities, the Company hereby establishes and complies with the following basic policy.

1. Organizational Response
The Company shall respond to unjustified demands and other acts by antisocial forces as an entire organization, including top management, rather than leaving the response to a specific department alone. In addition, the Company shall prioritize the safety of its officers and employees, and maintain an appropriate response system.

2. Collaboration with External Specialized Agencies
In preparation for unjustified demands and other acts by antisocial forces, the Company shall maintain close cooperation with external specialized agencies such as the police, the National Center for Removal of Criminal Organizations, and legal counsel on a regular basis to eliminate antisocial forces.

3. Severance of All Relationships, Including Transactions
The Company shall have no relationships whatsoever, including transactional relationships, with antisocial forces. The Company shall conduct necessary verification regarding its business partners. If it is found that a business partner is an antisocial force, or if a reasonable suspicion arises, the Company shall promptly terminate the relationship. Furthermore, the Company shall completely reject any unjustified demands from antisocial forces.

4. Legal Responses in Emergencies
The Company shall take resolute legal action, from both civil and criminal standpoints, against unjustified demands and other acts by antisocial forces in collaboration with external specialized agencies.

5. Prohibition of Under-the-Table Deals and Funding
Even if an unjustified demand from an antisocial force is based on the Company’s business activities or misconduct of its officers or employees, the Company shall never engage in under-the-table deals to conceal the facts. Furthermore, the Company shall not provide funds or any other benefits or facilities to antisocial forces.