Revised March 2011

1. Human rights

1-1. Respect the human rights/ Prohibit discrimination

Respect the human rights of all people and do not engage in discrimination or harassment on the grounds of race, color, gender, nationality, language, religion, creed, social origin, or any other such factors. Prohibit discrimination during the process of employment, and work toward the equal opportunity and fairness of treatment.

1-2. Prohibit harassment

Respect the human dignity of all people and do not use language that may disrespect them or engage in harassment. Do not use sexual language that may make others feel uncomfortable or engage in sexual harassment.

1-3. Prohibit child labor and forced labor

Do not engage in child labor or forced labor and do not accept any such practices from suppliers and other associates.

1-4. Respect the basic rights of employees

Respect the basic rights of employees, such as the right to organize and to bargain collectively, complying with local applicable laws and regulations.

2. Working conditions and environment

2-1. Ensure appropriate working conditions and working hours

Comply with labor laws and regulations and ensure that employment-related matters are managed appropriately in line with labor agreements and employment regulations.

2-2. Ensure safe, hygienic, and motivated working environments

Make every effort to ensure safe, hygienic and healthy working environments. Create a workplace where the employees feel pride and motivated.

3. Environment

3-1. Comply with environmental laws and regulations

Comply with domestic and overseas environmental laws and regulations, and act in accordance with internal regulations at every stage of our business from research and development, purchasing, production, sales and disposal.

3-2. Ensure environmental preservation

Make every effort to prevent pollution by reducing emissions of industrial waste and greenhouse gases, saving energy and resources, recycling industrial waste, and controlling chemical substances.

3-3. Preserve biodiversity

Make every effort to assess the impact of all business activities on the ecosystem and to ensure the sustainable use of resources and preserve biodiversity.

4. Products and services

4-1. Ensure products safety and reliability

Always provide highly reliable, safe products and services and take all necessary measures to prevent users and other concerned parties from sustaining physical injuries or property damage. Satisfy safety standards defined by applicable laws and regulations in each country when designing products.

4-2. Provide high-quality products and services

Strive to provide products and services of outstanding quality the viewpoints of customers and users.

5. International businesses and transactions

5-1. Comply with laws and respect international norms of behavior

Thoroughly research and comply with applicable laws and regulations in the relevant countries or regions when engaging in international businesses. Make every effort to respect the religion, customs, culture, and traditions in each country or region. In countries or regions where domestic laws and their enforcement do not meet social requirements, such as international norms of behavior, strive to respect such norms to the greatest extent possible

5-2. Observe laws and regulations governing imports and exports

Perform appropriate procedure when dealing with the import or export of products or technology regulated in laws and regulations. Ensure that no imported or exported products or technologies will be used for military purposes, such as the development of weapons (especially weapons of mass destruction).

6. Fair competition

6-1. Prohibit impediment to free competition

Always engage in free and fair competition with other companies, taking care to avoid any actions (cartels, bid rigging, division of markets, etc.) that violate competition laws in each country or region.

6-2. Prohibit abuse of superior positions

Do not to create a disadvantage for suppliers or contractors by abuse of a superior position.

7. Relations with customers, partners, and society

7-1. Prohibit bribes

Do not provide, promise, or offer benefits, monetary or otherwise, to any public officials or quasi public officials (including public officials working for overseas government bodies or international organizations) in return for access to facilities or other services. Similarly, in accordance with the relevant laws and regulations in each country or region, do not provide, promise, or offer benefits, monetary or otherwise, to customers and partners other than public divisions, in order to gain an unfair profit.

7-2. Prohibit excessive gifts and entertainment

Do not provide customers, partners or other concerned parties with excessive entertainment, gifts or other favors. Similarly, do not accept any such favors from partners or other parties.

7-3. Have fair relations with politics

Strive to build transparent and fair relations with political circles and comply with the internal regulations and applicable laws and regulations in each country or region concerning political donations or contributions.

7-4. Cut off all relations with antisocial forces

Adopt a resolute approach to and cut off all relations with antisocial individuals or groups to avoid giving in to any unreasonable demands.

7-5. Request legal compliance to partners

Request thorough legal compliance to all partners (suppliers, contractors, etc.) and provide guidance on any areas in which compliance is insufficient by using CSR guidelines, etc.

7-6. Contribute to society

Positively undertake social contribution activities in cooperation with local community activities, etc., and contribute to the community through our business.

8. Management and preservation of Company assets

8-1. Prohibit the improper use of Company assets

Properly manage company assets regardless of whether they are tangible or intangible (money, products, proprietary information, and office equipment, etc.), and do not fraudulently use or steal them.

8-2. Protect intellectual property

Make effective use of intellectual property rights, respect the rights of others and do not engage in any conduct that may infringe upon their rights.

8-3. Manage confidential information

Ensure that all confidential company information is managed appropriately and is not disclosed or leaked without authorization. Obtain confidential information concerning other companies only from authorized personnel by legitimate means, and manage and use the information properly.

8-4. Protect personal data

When handling personal data, ensure that all data is managed and handled appropriately in accordance with applicable laws, regulations, and internal regulations to avoid any unauthorized usage or leaks.

8-5. Use information system appropriately

Take protection against threats on the computer network, and manage to prevent damages to our company and concerned parties.

9. Disclosure of information

9-1. Disclose information in a timely manner

Ensure that financial data and other important information relating to the Furukawa Electric Group is disclosed appropriately and at the right time in accordance with applicable laws and regulations.

9-2. Achieve reliable financial reporting

Ensure that the facts disclosed within financial and other corporate data are accurate. Compile all financial statements in accordance with the applicable laws and regulations, corporate accounting principles and accounting standards and ensure that the details of the company's financial standing, profit and loss, and other figures are given correctly.

9-3. Prohibit insider trading

In the event that you obtain important, undisclosed information relating to a listed company or any of its subsidiaries, do not trade in the securities issued by the listed company until the information is made public. In the event that you obtain such information, do not disclose it to any other party until it is made public.

10. Duties and obligations of senior management and employees

10-1. Act in accordance with legal and ethical compliance

Fully understand that the Furukawa Electric Group regards compliance as "not only observing laws and regulations, but also as acting in accordance with the values and ethics required of the company and its employees as responsible members of society." Refrain from giving any instructions or orders that conflict with compliance.

10-2. Fulfill the responsibilities of senior management

In order to fulfill social responsibility for the Furukawa Electric Group, senior management shall take the initiative in complying with related laws, regulations, and this code, and shall continuously strive to ensure the proper operation and improvement of the internal control systems.

10-3. Prohibit conflicting actions with the interests of the company

Do not use information obtained as a result of the position or during the course of the work duties to make a profit for one's own or any third parties, or engage in any form of conducts that could adversely affect the company's profits. Do not engage in any form of conduct or accept any position that could potentially conflict with the interests of the company without obtaining authorization via the prescribed procedure.

10-4. Report illegal and improper conducts

Upon learning that any action in violation of laws, internal regulations, or this code is about to take place or has already taken place, report the matter to the Company (using the internal reporting system if there is one in place at the Company). The Company will respond to any such reports in good faith. Unless the report has been submitted for improper purposes, the reporting party shall not be disadvantaged in any way in terms of their position or treatment.

10-5. Cooperate with company investigations and prevent recurrence

When the company conducts an investigation of any violation or potential violation of applicable laws or regulations, cooperate with the investigation faithfully, and keep the relevant documents and data as they are and refrain from hiding, tampering with, or destroying them. In the event of a violation, take remedial action promptly and prevent a recurrence.

10-6. Crisis management and business continuity plans

Prepare emergency response measures for possible disasters and accidents in order to protect the safety of all people concerned, and fully inform people at the workplace of the measures. Develop business continuity plans for the prompt recovery of core businesses in unforeseeable circumstances.