Sustainability

In order to demonstrate the corporate philosophy in daily business activities and fulfill their social responsibility, the component companies of the our Group and each of their officers and employees observe the following Code of Conduct in all business activity.

• 1. General provisions
• 2. Basic principles of conduct
• 3. Relations with society
• 4. Relations with stockholders and investors
• 5. Relations with customers and business partners
• 6. Relations with employees
• 7. Management of Company assets, intellectual property and information

(As of June 26, 2008)

The mission of TSUBURAYA FIELDS HOLDINGS is to provide "The Greatest Leisure for All People," as in its corporate philosophy. Management's basic policy is to continuously enhance corporate value under that philosophy.
In the execution of business activities in accordance with that policy, management recognizes that fulfillment of corporate social responsibility is linked to improvement in the corporate value of the Company and its Group. In all aspects of business activity, all provisions of the Corporate Code of Conduct are to be strictly observed.

In order to achieve our mission of providing "The Greatest Leisure for All People," laws and regulations are to be strictly observed, and high ethical and moral consciousness preserved, so that not only in business but also in daily living, the following are the 7 basic principles of conduct under the motto of sincerity and integrity in all conduct.

(1) Observance of laws and regulations

In all business activity, we recognize that compliance with laws and regulations is the basis of corporate social responsibility.

(2) High ethical and moral consciousness

We will carry out all business activity with high ethical and moral consciousness.

(3) Observance of the public good

We will always carry out all business activity with good judgment, and avoid conduct contrary to the public good.

(4) Respect of basic human rights

In all business activity, we will respect the basic human rights of everyone.

(5) Fair business activity

In both domestic and overseas business activity, our conduct will be fair and sound.

(6) Respect for the environment

In awareness of the deep connection with environmental problems of corporate existence and business activity, we will strive for activity that respects the environment.

(7) Social contribution activity

As "good corporate citizens," we will undertake activity positively contributing to society.

In the strong consciousness that our business activity affects the health and sustainable development of society, our activity will be conducted as "good corporate citizens," prohibit contributions to anti-social elements detrimental to public order and safety, and strictly observe the following to preserve sound and normal relations with politics and administration for maintenance of the basics of social relations.

(1) Prohibition of anti-social conduct

We will confront and cut off all relations with anti-social forces and groups that threaten citizens' public order and safety.

(2) Policy on contributions to politics

In our relations with politics and administration, preserve soundness and normal relations, and observe related laws and regulations in regard to political funds, gifts, elections and political activity.

(3) Environmental protection

We will take positive measures for protection of the environment, including effective use and conservation of resources, appropriate waste disposal and recycling.

Seeking to become a corporation trusted by society, we will strictly observe the following as basic to full and timely disclosure of corporate information.

(1) Information disclosure

We will undertake wide communication with society, based on stockholders and investors, and disclose corporate information positively and fairly.

(2) Insider dealing restrictions

We will never trade securities or undertake other dealings using material non-public information obtained in the course of our work.

Seeking to become a corporation trusted by customers and business partners, we will take full account of the safety of products and services, and protection of information, strictly observing the following as basic to relations with customers and business partners.

(1) Safety and reliability of products and services

So that customers can use them with assurance, we strive to provide serviceable products and services that take safety and quality into account.

(2) Handling of customer information

We do not use for inappropriate purposes any customer or business partner confidential information obtained in the course of business. We follow all handling rules prescribed in laws and internal regulations, with stringent controls to prevent disclosure and leaks.

We seek management that respects people and the individuality and personalities of employees, provides a safe and pleasant working environment, and positions the following as basic to relations with employees.

(1) Respect for employee individuality and personality

We maximize respect for employee individuality and personality, and will bring about a free and creative corporate atmosphere.

(2) Realizing a pleasant workplace environment

We provide amplitude and richness to employees, to secure a safe and pleasant workplace environment.

The following are strictly observed in order to manage and operate various Company assets appropriately and lawfully.

(1) Management of Company assets

We will manage tangible and intangible Company assets appropriately in accordance with internal regulations.

(2) Protection of intellectual property

Appropriately and lawfully, we acquire, maintain, manage, and operate intellectual property (patents, trademarks, copyrights and others) necessary for business activity. And respecting the legitimate intellectual property rights of third parties, we do not infringe upon those rights or use them improperly.

(3) Appropriate information control

Fully recognizing the importance of information, we control appropriately all information held by the Company.