Introduction

At Tekscend Photomask Corp. and its group companies, we are committed to upholding the highest standards of Corporate Social Responsibility (CSR) across all business operations.
In addition to our established "Basic Procurement Policy," we have formulated the "Tekscend Photomask Group CSR Procurement Guidelines" to further define responsible procurement practices throughout the entire supply chain.
We expect our Suppliers and Subcontractors to comply with the Basic Procurement Policy, fully understand these Guidelines, and pursue continuous improvement.
We also ask that these principles be communicated and implemented across your own supply chains to promote responsible business practices.

These Guidelines will be reviewed and updated as necessary to reflect evolving social expectations and regulatory requirements. These Guidelines have been prepared with reference to the Responsible Business Alliance (RBA) Code of Conduct, Version 8.0.1 (2025), as well as the "Responsible Corporate Behavior Guidelines" issued by JEITA (Japan Electronics and Information Technology Industries Association).

Basic Procurement Policy

1. We maintain open windows for all Suppliers and Subcontractors fairly and conduct fair business interactions based on business ethics.
2. We operate in full compliance with applicable laws, rules, and regulations of Japan and other countries, as well as social norms.
3. We strictly manage information obtained through procurement activities.
4. We strive for environmental conservation and the reduction of environmental burden.
5. We pursue QCD (Quality, Cost, Delivery) to meet market needs.
6. We strive to build mutual cooperation and relationships of trust with Suppliers and Subcontractors.
7. CSR Procurement: We promote initiatives for CSR procurement throughout the supply chain to fulfill our corporate social responsibility.

Procurement Standards

1. Compliance with Laws and Respect for International Standards
2. Human Rights and Labor
3. Health and Safety
4. Environment
5. Fair Business and Ethics
6. Quality and Safety
7. Information Security
8. Business Continuity Plan
9. Establishment of Grievance Mechanism

1. Compliance with Laws and Respect for International Standards

Suppliers shall comply with all applicable laws, rules, and regulations of their home country and the countries or regions in which they operate, and shall conduct business activities in accordance with internationally recognized codes of conduct.

2. Human Rights and Labor

Suppliers shall comply with all applicable legal regulations and respect the human rights of workers in accordance with internationally recognized human rights standards, including the ILO Core Labor Standards.

(2-1) Prohibition of Forced Labor

Suppliers shall not engage in forced labor in any form, including bonded or indentured labor, debt bondage, involuntary or exploitative prison labor, slavery, or trafficking of persons. All work shall be voluntary, and workers shall have the right to freely leave their employment in accordance with applicable laws.

(2-2) Prohibition of Child Labor and Care for Young Workers

Suppliers shall not employ child labor at any stage of their operations. Children below the minimum working age as defined by applicable laws and regulations shall not be employed. Workers under the age of 18 ("Young Workers") shall not be assigned to work that may endanger their health or safety, including night work and overtime.

(2-3) Working Hours

Suppliers shall ensure that working hours comply with applicable legal limits and are managed in line with internationally recognized standards, including appropriate rest days and holidays.

(2-4) Wages and Benefits

Compensation paid to workers, including minimum wages, overtime pay, and legally mandated benefits and deductions, shall comply with all applicable wage laws. Suppliers are encouraged to provide wages sufficient to meet workers' basic needs, in line with the concept of a living wage.

(2-5) Prohibition of Inhumane Treatment

Participants shall respect the human rights of workers. Participants shall not engage in, permit, or threaten any form of harsh or inhumane treatment, including mental or physical coercion, abuse, or harassment.

(2-6) Non-Discrimination

Suppliers shall not engage in discrimination or harassment based on race, ethnicity, national origin, religion, age, physical characteristics, disability, gender, marital status, sexual orientation, gender identity, or any other status protected under applicable laws.

(2-7) Freedom of Association and Collective Bargaining

In compliance with applicable laws and regulations, suppliers shall respect workers' rights to freedom of association and collective bargaining regarding working conditions and wages.

3. Health and Safety

Suppliers shall comply with all relevant laws and regulations and shall establish and maintain a safe and healthy working environment in accordance with ILO occupational health and safety guidelines, with the objective of preventing work related injuries and illnesses.

(3-1) Occupational Safety

Potential worker exposure to health and safety hazards shall be identified and assessed, and risks shall be controlled through appropriate design, engineering, and administrative measures. Reasonable accommodations shall be provided for workers who require them, including pregnant women and nursing mothers.

(3-2) Emergency Preparedness

Potential emergency situations and events, including disasters and accidents that may compromise human life and safety, shall be identified and assessed, including an evaluation of the likelihood of occurrence. Emergency plans and response procedures shall be established and implemented to minimize harm to workers and property, including the installation of necessary equipment and the provision of training and drills.

(3-3) Occupational Injury and Illness

Suppliers shall establish and maintain procedures and systems to prevent, manage, monitor, and report occupational injuries and illnesses, and to implement appropriate countermeasures and corrective actions.

(3-4) Industrial Hygiene

Suppliers shall identify, assess, and control worker exposure to chemical, biological, and physical agents in the workplace.

(3-5) Physically Demanding Work

Suppliers shall identify and assess worker exposure to hazards associated with physically demanding tasks and shall implement appropriate measures to prevent occupational injury and illness.

(3-6) Machine Safeguarding

Suppliers shall identify and assess safety hazards associated with production and other machinery used in operations and shall implement appropriate safeguarding and risk control measures.

(3-7) Sanitation, Food, and Housing

Suppliers shall ensure that facilities provided to workers, including dormitories, canteens, and sanitary facilities, are safe and healthy. Such facilities shall also be equipped with appropriate emergency exits and evacuation routes.

(3-8) Health and Safety Communication

Suppliers shall provide workers with appropriate workplace health and safety information and training in a language they understand, covering occupational hazards to which they may be exposed. Suppliers must also establish and maintain a mechanism that enables workers to provide feedback and raise concerns regarding health and safety.

(3-9) Worker Health Management

Suppliers shall provide and maintain appropriate health management for all employees.

4. Environment

Suppliers must take appropriate measures to address global environmental issues, including resource depletion, climate change, and environmental pollution, while also managing local environmental impacts to protect the health and safety of surrounding communities.

(4-1) Environmental Permits and Reporting

Suppliers shall obtain, maintain, and keep current all required environmental permits, approvals, and registrations in accordance with applicable laws and regulations at the business location, and shall comply with all related reporting requirements.

(4-2) Energy Consumption and Greenhouse Gas Emissions

Suppliers shall continuously improve energy efficiency and implement measures to reduce energy consumption and greenhouse gas emissions.

(4-3) Air Emissions

Suppliers shall implement appropriate measures, in compliance with applicable laws and regulations, to reduce emissions of hazardous substances into the atmosphere.

(4-4) Water Management

Suppliers shall comply with applicable laws and regulations by documenting and monitoring water sources, water use, and water discharge, and by implementing measures to conserve water. All wastewater shall be appropriately characterized, monitored, controlled, and treated as required prior to discharge or disposal. Suppliers must also identify and properly manage sources of contamination that may cause water pollution.

(4-5) Pollution Prevention and Resource Conservation

Suppliers shall comply with applicable laws and regulations and implement appropriate management practices to promote the reduction, reuse, and recycling of materials, ensuring the effective use of resources and minimizing waste generation.

(4-6) Hazardous Substances

Suppliers shall identify, label, and manage chemicals, waste, and other hazardous materials to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal in compliance with applicable laws and regulations.

(4-7) Materials Restrictions

Suppliers shall comply with all applicable laws, regulations, and relevant standards regarding the prohibition or restriction of specific substances in products.

5. Fair Business and Ethics

Suppliers must conduct business activities in compliance with applicable laws and regulations and in accordance with the highest standards of ethics.

(5-1) Business Integrity

Suppliers shall implement and enforce a zero tolerance policy prohibiting all forms of bribery, corruption, extortion, and embezzlement.

(5-2) No Improper Advantage

Suppliers shall not, directly or indirectly, offer, promise, provide, authorize, solicit, or accept bribes or other improper advantages, including through promises, offers, or authorizations.

(5-3) Disclosure of Information

Suppliers shall disclose accurate and complete information regarding labor, health and safety, environmental practices, business activities, organizational structure, financial condition, and performance in accordance with applicable regulations and prevailing industry practices. Falsification of records or any form of misrepresentation is strictly prohibited.

(5-4) Intellectual Property

Suppliers shall respect intellectual property rights and shall ensure that any transfer of technology or know how is conducted in a manner that protects such rights. Suppliers shall also safeguard the intellectual property rights of third parties, including customers and suppliers.

(5-5) Fair Business, Advertising, and Competition

Suppliers shall uphold standards of fair business practices, advertising, and competition.

(5-6) Protection of Identity and Non-Retaliation

Suppliers shall protect the confidentiality of information related to whistleblowing and shall ensure the anonymity of whistleblowers. Suppliers shall prohibit retaliation against whistleblowers.

(5-7) Responsible Sourcing of Minerals

Suppliers shall exercise due diligence to ensure that minerals such as tantalum, tin, tungsten, and gold contained in the products they manufacture are responsibly sourced and do not directly or indirectly contribute to serious human rights abuses, environmental destruction, corruption, or conflict in conflict affected and high risk areas.

(5-8) Appropriate Trade Management

Suppliers shall establish and maintain an appropriate management system to ensure compliance with applicable domestic and international laws and regulations governing the import and export of regulated goods and technologies and shall conduct appropriate import and export procedures.

(5-9) Exclusion of Anti-Social Forces

Suppliers shall not engage in or maintain any relationships with forces that threaten the order and safety of civil society and shall comply with all applicable laws, regulations, and social norms.

6. Quality and Safety

Suppliers must ensure the safety and quality of the products and services they provide and shall provide accurate and reliable information.

(6-1) Ensuring Product Safety

Suppliers shall design, manufacture, and sell products that comply with applicable product safety standards under the laws and regulations of each country and must ensure adequate product safety.

(6-2) Quality Management

Suppliers must comply with all applicable laws and regulations regarding the quality of products and services and shall meet their own quality standards and customer requirements.

(6-3) Providing Accurate Product and Service Information

Suppliers shall provide accurate, complete, and non misleading information regarding their products and services.

7. Information Security

Suppliers must prevent the leakage of confidential and personal information and shall strengthen information security.

(7-1) Defense against Cyber Attacks

Suppliers shall implement and maintain appropriate defensive measures against cybersecurity threats, including cyber-attacks, to prevent harm to the company and third parties.

(7-2) Privacy (Protection of Personal Information)

Suppliers shall comply with applicable privacy and information security laws and regulatory requirements in the collection, use, management, and protection of personal information of all individuals, including suppliers, customers, consumers, and employees.

(7-3) Prevention of Leakage of Confidential Information

Suppliers shall appropriately manage and protect confidential information received from their own company, as well as from customers and third parties.

8. Business Continuity Plan

Suppliers must be prepared to promptly resume production activities to fulfill their supply responsibilities in the event that the company or its business partners are affected by a large scale natural disaster or similar event.

(8-1) Formulation and Preparation of Business Continuity Plan

Suppliers shall formulate a Business Continuity Plan (BCP) that identifies and assesses risks to business continuity, evaluates their potential impact, outlines necessary medium to long term proactive measures, and summarizes the status of their implementation.

9. Establishment of Grievance Mechanism

Suppliers shall establish and maintain a grievance mechanism to prevent misconduct by the company and within the supply chain, which is accessible to stakeholders, including workers and suppliers.