Introduction

At Tekscend Photomask Corp. and its group companies, in response to the growing interest in Corporate Social Responsibility (CSR), we are actively working to fulfill the highest standards of social responsibility across all our business operations.
While we have established a "Basic Procurement Policy" for our purchasing activities, we have formulated the "Tekscend Photomask Group CSR Procurement Guidelines," which further concretize our procurement standards to realize CSR procurement throughout the entire supply chain.
We request that our Suppliers and Subcontractors agree to the "Basic Procurement Policy," understand the "Tekscend Photomask Group CSR Procurement Guidelines," and engage in continuous improvement.
Furthermore, we ask that you communicate these guidelines to your own suppliers and subcontractors within your supply chain and promote CSR activities.
Please note that these guidelines will be reviewed and revised as appropriate in accordance with changes in social demands.

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 not only comply with applicable laws, rules, and regulations of their own country and the countries/regions where they operate but also conduct business activities with respect for international codes of conduct.

2. Human Rights and Labor

Suppliers must not only comply with applicable legal regulations but also respect the human rights of workers by referring to international human rights standards, including the ILO Core Labor Standards.

(2-1) Prohibition of Forced Labor

Forced labor in any form, including but not limited to, bonded (including debt bondage) or indentured labor, involuntary or exploitative prison labor, slavery, or trafficking of persons is not permitted. Furthermore, all work shall be voluntary, and the right of workers to leave work or terminate their employment shall be protected.

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

Child labor shall not be used in any stage of manufacturing involving the employment of children under the minimum working age of the region. Workers under the age of 18 (Young Workers) shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime.

(2-3) Working Hours

Working hours shall not exceed the maximum set by local law. Suppliers must properly manage workers' working hours and holidays/days off, taking into consideration international standards.

(2-4) Wages and Benefits

Compensation paid to workers (including minimum wages, overtime hours, and legally mandated benefits and wage deductions) shall comply with all applicable wage laws. It is also recommended to consider the payment of wages sufficient to meet basic needs (living wages).

(2-5) Prohibition of Inhumane Treatment

Participants shall commit to respect the human rights of workers. There shall be no harsh or inhumane treatment including mental or physical coercion, abuse, harassment, or any other such treatment, nor is there to be the threat of any such treatment.

(2-6) Non-Discrimination

Companies 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 other status.

(2-7) Freedom of Association and Collective Bargaining

In compliance with local laws and regulations, suppliers shall respect the right of workers to organize as a means of realizing labor-management consultation regarding working environments and wage levels.

3. Health and Safety

Suppliers must not only comply with relevant laws and regulations but also pay attention to ILO health and safety guidelines, minimizing work-related injuries and illnesses, and establishing a safe and healthy working environment.

(3-1) Occupational Safety

Worker potential for exposure to health and safety hazards shall be identified and assessed, and safety shall be ensured through appropriate design, engineering, and administrative controls. Reasonable accommodations must be provided especially for pregnant women and nursing mothers.

(3-2) Emergency Preparedness

Potential emergency situations and events (including disasters and accidents that compromise human life and safety) shall be identified and assessed (including the likelihood of occurrence). Emergency plans and response procedures--including minimizing harm to workers and property, installing necessary equipment, and providing training and drills--must be implemented.

(3-3) Occupational Injury and Illness

Procedures and systems shall be in place to prevent, manage, track, and report occupational injuries and illnesses, and to implement appropriate countermeasures and corrective actions.

(3-4) Industrial Hygiene

Worker exposure to chemical, biological, and physical agents in the workplace shall be identified, evaluated, and controlled.

(3-5) Physically Demanding Work

Worker exposure to the hazards of physically demanding tasks shall be identified and evaluated, and properly managed to prevent occupational injury and illness.

(3-6) Machine Safeguarding

Production and other machinery used in operations shall be evaluated for safety hazards, and appropriate safety measures shall be implemented.

(3-7) Sanitation, Food, and Housing

The health and safety of facilities provided to workers (dormitories, canteens, toilets, etc.) shall be appropriately ensured. Such facilities must also ensure appropriate emergency egress.

(3-8) Health and Safety Communication

Participants shall provide workers with appropriate workplace health and safety information and training in the language of the worker or in a language the worker can understand regarding various occupational hazards they may be exposed to. Additionally, a mechanism for feedback on safety-related opinions from workers is required.

(3-9) Worker Health Management

Appropriate health management shall be provided for all employees.

4. Environment

Suppliers must actively address global environmental issues such as resource depletion, climate change, and environmental pollution, while also considering local environmental issues to safeguard the health and safety of the community.

(4-1) Environmental Permits and Reporting

All required environmental permits, approvals, and registrations necessary for the business shall be obtained, maintained, and kept current in accordance with the laws and regulations of the business location, and their reporting requirements shall be followed.

(4-2) Energy Consumption and Greenhouse Gas Emissions

Suppliers shall strive to improve energy efficiency and engage in continuous reduction activities for energy consumption and greenhouse gas emissions.

(4-3) Air Emissions

In compliance with relevant laws and regulations, appropriate measures shall be implemented to reduce emissions of hazardous substances into the atmosphere.

(4-4) Water Management

In compliance with laws and regulations, suppliers shall document and monitor water sources, use, and discharge, and conserve water. All wastewater shall be characterized, monitored, controlled, and treated as required prior to discharge or disposal. In addition, sources of contamination that may cause water pollution shall be identified and managed appropriately.

(4-5) Pollution Prevention and Resource Conservation

By complying with laws and regulations and implementing appropriate management, suppliers shall promote reduction, reuse, and recycling to ensure the effective use of resources and minimize the generation of waste.

(4-6) Hazardous Substances

Chemicals, waste, and other materials posing a hazard to humans or the environment shall be identified, labeled, and managed to ensure their safe handling, movement, storage, use, recycling or reuse, and disposal in compliance with laws and regulations.

(4-7) Materials Restrictions

Suppliers shall adhere to all applicable laws, regulations, and related standards regarding the prohibition or restriction of specific substances in products.

5. Fair Business and Ethics

Suppliers must conduct business activities based not only on legal compliance but also on the highest standards of ethics.

(5-1) Business Integrity

Participants shall have a zero-tolerance policy to prohibit any and all forms of bribery, corruption, extortion, and embezzlement.

(5-2) No Improper Advantage

Bribes or other means of obtaining undue or improper advantage, such as promises, offers, or authorizations, shall not be provided or accepted.

(5-3) Disclosure of Information

Information regarding labor, health and safety, environmental practices, business activities, organizational structure, financial situation, and performance shall be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation is unacceptable.

(5-4) Intellectual Property

Intellectual property rights shall be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property rights. Intellectual property of third parties, including customers and suppliers, shall also be safeguarded.

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

Standards of fair business, advertising, and competition shall be upheld.

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

The confidentiality of information related to whistleblowing and the anonymity of whistleblowers shall be protected, and retaliation against whistleblowers shall be eliminated.

(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 do not cause or contribute to serious human rights abuses, environmental destruction, corruption, or conflict in conflict-affected and high-risk areas.

(5-8) Appropriate Trade Management

Regarding the import and export of goods and technologies regulated by domestic and international laws and regulations, suppliers shall establish a management system and conduct appropriate import/export procedures.

(5-9) Exclusion of Anti-Social Forces

Suppliers shall cut off all relationships with forces that threaten the order and safety of civil society and comply with laws, ordinances, and all other social norms.

6. Quality and Safety

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

(6-1) Ensuring Product Safety

Suppliers must fulfill their responsibilities as suppliers by designing, manufacturing, and selling products that meet the safety standards stipulated by the laws and regulations of each country and ensure sufficient product safety.

(6-2) Quality Management

Suppliers shall not only comply with all applicable laws and regulations regarding the quality of products and services but also comply with their own quality standards and customer requirements.

(6-3) Providing Accurate Product and Service Information

Accurate and non-misleading information regarding products and services shall be provided.

7. Information Security

Suppliers need to prevent the leakage of confidential and personal information and strengthen information security.

(7-1) Defense against Cyber Attacks

Defensive measures against threats such as cyber attacks shall be taken and managed to prevent damage to the company and others.

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

Participants shall comply with privacy and information security laws and regulatory requirements when personal information of all individuals, including suppliers, customers, consumers, and employees, is managed and protected.

(7-3) Prevention of Leakage of Confidential Information

Confidential information received not only from one's own company but also from customers and third parties shall be appropriately managed and protected.

8. Business Continuity Plan

Suppliers must be prepared to resume production activities as quickly as possible in order 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

It is necessary to formulate a Business Continuity Plan (BCP) that identifies and assesses risks that hinder business continuity, scrutinizes the impact on business, outlines necessary medium- to long-term proactive measures, and summarizes the status of those initiatives.

9. Establishment of Grievance Mechanism

To prevent misconduct by the company and within the supply chain, a grievance mechanism available to stakeholders, including workers and suppliers, shall be established.