Code of conduct (hereafter referred as
"Code") was established in order to enhance compliance
management - the foundation for the accompanied
growth so that all members of the organization may grow within the community. Staffs and
employees of EM Tech should fully obey the law and rules of the country in
which the business office is located, ensurea safe working environment, establish and maintain the business
management process in which the stakeholders can be respected, and operate the
In this Code the
requirements for all staffs and employees of EM Tech are presented. This code is applied to the
all forms of structures designing, manufacturing, supplying and selling the
parts used for the production of the goods and services. All
employeesandmembers arerequired to comply withthe Code, and also should
require all sub-network of suppliers providing assembly, parts, raw materials
and package to aomply.
responsibilityfor complying withregulationsis applicabletothe
parties, and if corrective actionforviolationsis not conducted within the required due date, the
appropriate sanction may be taken.
Codeisbased on theEICCCode of Conduct, and the global standards and guidelinesestablished bythe agenciessuch as theILOand ISO can be used as the
additional information. In addition,due tointernal and externalchangemanagement policies, the Code may be amended.
Whenthere is any conflict betweenthis Code and local regulations,
the higher standards shall prevail.
￭Human Rights andLabor
This Code presents
the level of the standards prevailing inthe international community, and should ensure human rightsandthe dignity oftheirworkers. This Code is will be applied toalltypes
of employees including temporary workers, migrant workers,studentworkers, etc.
of the forced labor
Allworkmust bevoluntary.Forcedworkers,workers according tohumanredemptioncontract,
not beemployed. This includesall actions of moving, hiring,
and transferring socially disadvantaged by means of intimidation,extortion,coercion, abduction,
and fraud for the purpose oflabor
exploitation. The transfer of ggovernment-issuedidentification,passports orwork permits should not be required as the employment conditionsofworkers. Excessivefeesfor the purpose ofemploymentare not allowed, and the details of
all feescharged toworkersshould be open to the workers In addition, working conditionsmustbe
documented andforwarded in a language understood byworkers.
Prohibitionof child labor The employment of child workers is strictly prohibited. "Child"is the employ under 15 years old -the age when compulsory education ends or theemployeewiththe
highestage among the employees of statutoryminimum age foremployment in accordance withlocal laws. Ifthe childworkers arefound, the immediatecountermeasures
must be taken. The company must immediately stop the employment of the
child workers, and improve the age verification process in the employment
process. If traineeprograms are managed,they must comply withlocal laws and
regulations. Although the company canhire youthworkers at the age higher than thestatutoryminimum age, workersunder the age of 18 should notperformhazardousworkin terms
ofhealth and safety.
withworking hours Working hoursper weekmust not exceed the maximum time specified inthelocal laws and regulations. Work hoursof one weekshould
not exceed60 hours including the overtimehoursper week
except forspecial circumstances such as an emergencyor naturaldisaster.However, if the statuary allowedworkingtime in the localcountryis less than60 hoursweekly, then it is needed tocomply withlocal laws and regulations. Workerson dutyseven days a weekto ensurethatat least
one day's absence. At least one day’s holidays should be guaranteed to
the workers among the 7 working days a week.
Wagespaid toworkersmust includeitemssuch asthe minimum
wage, overtimepay,legally mandatedbenefits and must be complied with alllocal laws and regulations. Allovertimemust be madevoluntarilywith the consent ofthe employer,
and, depending onlocal laws and
regulations,the overtime working payment higher thannormal wagemust be paid. The pay orcutfinancialrequirementsviolatinglocal laws as a disciplinary actionwill not
be accepted. Payment items and criteria of worker’s
ages should be provided in a language understood byworkers
through benefitstatement ora
writtenrecordpayrollhistory, andthecompany's intranet.
Sexual harassment,sexual abuse,corporal punishment, mentalor physicalcoercion, andinhumane treatment, including rough abuse to the workers should not exist have,
and also the threatof suchtreatment should not be taken. The regulatorypolicies and procedures for ensuring humane treatment of the workers
should be defined and fullydescribed to the workers.
Non-Discrimination Workers shouldnot receive theharassment or illegaldiscrimination. They should not
reasons based on the race, color,age, gender,
sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation,
unionstatus, marital status in the employment practices such as hiring andpromotion, compensation, and training opportunities. Besides the
exceptional cases according to the local laws andregulations or required forworkplace safety, the company
should not conduct medical examinationsor
unlawfully using their results for the purpose of discrimination.
￭Health and Safety
should be recognized that the activitiesto
ensure thesafety and healthof
workersis essentialin all
activities conducted in company works such asthe production of the product. Depending onlocal laws and regulations the efforts to build and maintaina safe and healthy workplace should be made.
Safety In order tocontrol the exposure of the workers to potential safetyhazards(eg,electrical shock, fire,
vehicles, and fall hazards, etc.) the properdesign, engineering andadministrative
procedures(lock, protective devices) should be
built and at the same time continuous safety
trainingmust be conducted. If
the risk factorscannotadequately be controlled
through the above mentioned means, then appropriate personal protective
equipmentmust be provided to the workers. It should be
ensured that the workers areable tofreely raise the issuesconcerning
Preparedness Potentiallypossibleemergencies andaccidentsmust be identified and assessedin advance. Reports,announcements
to the workers andevacuation procedures would be made, and emergencyplans andresponse procedures including ensuring emergencyevacuation drillstargetedworkers, escape facilities,fire detection and suppression
equipment, the recovery plan should be established and
implemented to minimizethedamage caused by the
emergency and accidents.
accidents and diseases prevention
The systemsand procedures to prevent,manage, track and report the workers'industrial
accidents anddisease should be built. This systems and
procedures should include the provisions as follows:A) to encourageemployeesto reportfreely,
B) to classify andrecordoccupational accidents and diseases, C) to providethenecessarymedical
treatment, D) to investigatethe cause ofeach case and implementthecorrective action toremove it, and by theseE) to support theemployee's return who left the work due to the industrial accident and disease.
ExposureReduction The exposure of the workers to the chemicals usedin the workplace,biologicalfactors, such as pathogens,viruses, and physical factors including high
temperature and radiation should be identified, evaluated, and
controlled. The problem on thehealth and safetyof workers due tothe above mentioned harmfulfactorsshould be avoided
through the technical controls such as the calibration and improvement of theproduction facility and the
administrative controlaccording to the legal and institutional requirements. If the risk factorscannot beadequately controlled by these means, then the health ofworkers should be protected
through appropriate personal protective equipmentprovision
andthe program operation.
including repeated manual jobs or standing for a long time, lifting heavy
things, and assemblywork requiring a lot ofphysical strengthconsumption should be identified,evaluated andcontrolled.
In using machinery, equipmentand
facilities needed for the production their safety
should be assessed. In case of using the machine through which the workers are
exposed to the danger, physicalprotection devices,interlocks,
and barriers must beprovided and properly
dormitoryand sanitation facility Clean toiletandpotable
water facilities should be provided to the workers with the space to cook and storefoodhygienically, and the place for eating a
meal. The dormitory offered toemployeesmust beclean, safe, and provided with appropriateemergency evacuationfacilities,
heating and ventilation,a reasonablelevel ofaccessrights,
operationsmust bethoroughlymanaged. The environmental impactthat
occurswhen providing the product and service
should fully understood and the efforts to reduce them should be made. Environmental
lawsand regulations related to the management anddisposal, recycling of chemicals andwaste, industrial water management and reuse,greenhouse
gasand atmospheric emissions must be observed. If the environmental
standardsrequired for the design and production of the
products is needed in other contracts, they should be observed, too.
environmental certifications and licenses
All environmental certifications and licenses necessary for the business
operations(eg,air emissionfacilities, etc.) and registrations should acquired,
maintained, and managed, and the recentamendmentsshould be reflected to them. Andthe requirements necessary for getting licenses and certifications
such as managing and reportingmust be complied.
preventionand resource use reduction
The company should trytoreduce oreliminate allforms of waste, including waste water according
tolocal laws and regulations through the methods such as productionprocess improvement,
maintenance enhancement,plantprocesschanges, raw materialsubstitution,recyclingand reuse ofmaterials.
Managementof Hazardous Substances Inthe case of the dischargeof hazardous substances chemicalsand other substances with the possibility
ofenvironmental pollution should be identified, and must be treated
safe, moved, stored, used, reused and recycled, and disposed. The local laws and regulations prohibiting or regulating the use and
treatment of certain substances should be observed.
andsolid waste arising fromindustrial
processesand sanitation facilities in the process of
the business operation should be emitted according toapplicable
laws and regulations,or before their disposal the
properties of those materials should be identified and monitored, and then they
should be appropriately treated and controlled.
Pollutants The properties of volatileorganic
chemicals,aerosols,corrosives,fine powder, ozone depleting substances,
greenhouse gases andcombustionby-productsgenerated inthe process,before their emissions to the air, should be
identified and monitored, and then they should be appropriately treated and controlled
according tolocal laws and regulations.
of substances regulations inproducts Thelocal lawsand
regulations associated with the use prohibition or restriction ofcertain
substances including indicating the information about the materials at
the time of recycling and disposal of the materials, and the requirement of the
related agency should be observed. In addition,hazardous
chemicalsmanagementguideline 「EI-4463」must be observed.
￭Ethical management Management activitiesofthebusinessoperationsshould be complied with alllocal lawsand regulations, and are required to
maintain thehighest ethical standards.
In relation toanycorporate transactionthe highest level ofintegrity is required. A zero
tolerance policyrelated with anti-corruption should be
established which prohibits the any form of action to give or receive bribe
contrary to the local regulations and laws for the purpose of influencingthe decision-making process, corruption, forcingandembezzlement(including the
case when bribery is promised, provided, grantedor tolerated), rebates, etc. The
appropriate level ofmonitoring andenforcement
proceduresmust be executed to evaluate the compliance
According to the relevant
laws and regulations, and generalindustrypractice management activities,organizational structure, financial
condition andperformance information should be accuratelyrecorded and theinformationmust be disclosed.
Intellectual property rightsmust berespected. The transfer of technology and know-howis must be donein a way protecting intellectual property rights.
trade, advertising and competition
The standard of fair trade, advertising, sales, and competition
must be observed.
According tothelaws and regulationsrelevantwith identity
protection the program for the whistleblowerprotection and ensuring his confidentiality
should be introduced and maintained. According to relevant laws and regulations the process
through which the workers may raiseissuesor exchange ideas without fear of retaliation should be built.
The prohibition of
the use of minerals from conflict areasin Africa
Acknowledging that tantalum,tin, tungsten, gold used in products directly
or indirectlybecomes the financial resources for the armed