Article 1 (Purpose)

All executives and employees of Mercury Co., Ltd. establish and practice ethical decision-making and standards of conduct.

Article 2 (Scope of Application)

This Code of Ethical Conduct applies to all executives and employees performing duties at Mercury Co., Ltd.

Article 3 (Compliance with Laws and Internal Regulations)

① Executives and employees shall comply with relevant laws and regulations (“laws”) and the company’s internal rules (“internal regulations”) when performing their duties.
② If the interpretation or application of laws or internal regulations is unclear, executives and employees shall seek advice from relevant departments to confirm legality.

Article 4 (Definitions)

① “Company” refers to Mercury Co., Ltd.
② “Money or valuables” refers to cash, checks, gift certificates, securities, goods, etc.
③ “Acceptance of money or valuables” includes not only receiving or agreeing to receive such items, but also economic benefits such as debt forgiveness, guarantees, collateral provision, or discounted real estate transactions.
④ “Entertainment” refers to receiving benefits such as sexual favors, meals, alcohol, sports (including golf), performances, or overseas travel.
⑤ “Convenience” refers to receiving benefits such as transportation, accommodation, tour guidance, or event support.
⑥ “Gambling” refers to games such as card games, betting golf, casinos, etc., and “illegal gambling” refers to legally prohibited activities such as illegal sports betting or illegal casinos.
⑦ “Stakeholders” refers to individuals, corporations, or organizations that may be directly or indirectly affected in their rights or interests through business activities, including executives, employees, customers, and partners.
⑧ “Whistleblower” refers to executives, employees, partner companies, or customer company employees who recognize and report violations of this Code.
⑨ “Partners” refers to all companies providing goods or services to the Company.
⑩ “Host country” refers to the country where dispatched employees are stationed.
⑪ “Material non-public information” refers to undisclosed information that may significantly affect investment decisions, such as mergers, new investments, changes in business purpose, or suspension of operations.

Article 5 (Fair Treatment and Protection of Employees)

① The Company respects its employees and evaluates and rewards their abilities and performance fairly.
② The Company establishes necessary systems and regulations to develop employees into top-tier talent and provides an optimal working environment.
③ The Company shall not discriminate in employment or promotion based on gender, family background, education, age, or region of origin.
④ The Company establishes policies and welfare systems to promote employee health, and employees shall manage their own health and hygiene.
⑤ The Company must protect the safety of employees, customers, and local communities, and prioritize safety in the event of accidents.
1. The Company provides thorough safety training for accident prevention and response.
2. The Company conducts regular inspections of facilities and works to prevent accidents such as fires.
3. Employees shall protect their own safety and comply with safety-related laws and standards.

Article 6 (Responsibilities to Shareholders)

① The Company maximizes corporate value and profits through efficient management.
② The Company respects shareholders’ rights, including the right to know, and reflects them in management.
③ The Company transparently discloses corporate information in accordance with laws and complies with accounting and reporting regulations.
④ The Company conducts fair and transparent transactions with subsidiaries, customers, and partners.
⑤ The Company and its employees shall not trade securities using material non-public information or provide such information to third parties.

Article 7 (Responsibilities to the State and Society)

① The Company contributes to national and social development by creating social value through responsible management.
② The Company encourages employee participation in social service activities for community development.
③ The Company and employees shall not engage in political activities or provide illegal political funds, nor conduct political activities at the workplace.
④ The Company and employees recognize the importance of environmental issues and comply with environmental laws while striving to protect nature and prevent pollution.
1. The Company maintains and manages facilities to prevent and improve environmental pollution.
2. The Company strives to protect local environments and ensure a pleasant living environment for residents.

Article 8 (Work Discipline)

① Employees shall act honestly with pride and integrity.
② Employees shall share the Company’s management philosophy and vision and perform their assigned duties to the best of their abilities.
③ Employees shall not engage in unethical or immoral behavior that could harm personal dignity or the Company’s reputation.
④ Employees shall clearly understand their authority and responsibility and perform duties lawfully and properly.
⑤ Employees shall not engage in internet gaming, sports betting, or visit non-work-related venues during working hours.
⑥ Employees shall not form factions or private organizations based on personal relationships.
⑦ Employees shall not use material non-public information for personal gain or provide it to others, nor abuse their position for private benefit.

Article 9 (Superior–Subordinate Relationships)

① Superiors shall not exert pressure regarding partner selection and shall follow objective procedures.
② Superiors shall not issue improper orders, and employees must report improper conduct; failure to do so may result in disciplinary action.
③ Superiors shall not demand gifts or entertainment or force subordinates into personal tasks.
④ Financial transactions between employees, especially between superiors and subordinates, are strictly prohibited.
⑤ Employees shall not solicit improper favors or provide or promise economic benefits in return.
⑥ The exchange of congratulatory gifts related to promotions or appointments is prohibited.
⑦ Subordinates shall not give farewell money to superiors upon transfers or business trips.

Article 10 (Customer Protection)

① Employees shall provide quality products at reasonable prices and strive for customer satisfaction.
② Employees shall comply with consumer protection laws.
③ Employees shall not leak or misuse customers’ personal information.

Article 11 (Mutual Growth and Cooperation)

① Employees shall treat partners fairly and courteously.
② Employees shall not demand improper economic benefits or engage in unfair trade practices.
③ Employees shall comply with fair trade and subcontracting laws.
④ Employees shall not exploit partners’ difficulties for unethical gain.
⑤ Employees shall conduct business discussions in transparent and open environments.
⑥ Employees shall not misuse partner information for personal benefit.
⑦ Partners shall be selected based on objective and fair criteria.
⑧ Employees shall prioritize Company interests and avoid collusion or favoritism.
⑨ Employees shall not register partners with personal interests without prior approval.
⑩ Employees shall not make recruitment or personnel-related requests to partners.
⑪ Employees shall not inform partners of personal family events.

Article 12 (Compliance with Global Code of Ethics)

① Overseas employees shall comply with domestic laws, internal regulations, and host country laws.
② Overseas employees shall respect local cultures and customs.
③ Overseas employees shall not engage in unethical behavior that may damage the Company’s image or business.

Article 13 (Prohibition of Embezzlement, Misappropriation, and Breach of Trust)

① Employees shall not embezzle, misappropriate, divert, or unlawfully use the assets of the Company or customers.
② Employees shall not use Company assets, products, or materials for personal benefit.
③ Employees shall not engage in illegal acts for financial gain or allow third parties to gain such benefits, causing damage to the Company.

Article 14 (Prohibition of Acceptance of Entertainment and Convenience)

① Employees shall not receive money, valuables, entertainment, or convenience from stakeholders.
② Employees shall not pass on expenses such as meals or event costs to stakeholders.
③ Employees shall not receive transportation, accommodation, or any other convenience for personal or business purposes from stakeholders.
④ Employees shall not engage in gambling or speculative entertainment with stakeholders.
⑤ Employees shall not engage in financial transactions such as loans or guarantees with stakeholders.
⑥ Employees shall not request stakeholders to pay credit card bills, outstanding debts, or loans, nor accept such offers.
⑦ Employees shall not engage in leasing, sale, or brokerage of real estate with stakeholders.
⑧ Employees shall not acquire or receive stakes or assets from stakeholders, nor make joint investments without prior Company approval.
⑨ Employees shall not use Company assets or personnel for private purposes or provide them to stakeholders without approval.
⑩ Employees shall not request or accept future employment, job placement, or contractual guarantees from stakeholders.
⑪ This Article applies equally to acts conducted by spouses, immediate family members, or relatives on behalf of employees.

Article 15 (Prohibition of Illegal Gambling)

① Employees shall not engage in illegal sports betting or unlawful gambling activities.
② Employees shall not introduce or encourage illegal gambling and must report such activities immediately if discovered.

Article 16 (Prohibition of Sexual Harassment and Workplace Harassment)

① Employees shall not engage in acts causing sexual humiliation or discomfort, nor impose disadvantages due to rejection of such conduct.
1. Physical contact or touching specific body parts
2. Verbal sexual harassment such as obscene jokes
3. Forcing stereotypical gender roles, including serving alcohol at company gatherings
4. Displaying or sharing obscene materials
5. Any other acts causing sexual offense under social norms
② Employees shall not abuse their position to cause physical or mental suffering or deteriorate the work environment.
1. Abuse of authority in evaluations or promotions
2. Assigning personal errands to subordinates
3. Repeated insults or creating negative public opinion against specific employees

Article 17 (Drunk Driving)

① Employees shall not drive under the influence of alcohol and must report any license suspension or revocation immediately.
② Employees shall not drive while their license is suspended or revoked.

Article 18 (Prohibition of Concurrent Employment)

① Employees shall not conduct business with the Company or trade using third-party names without approval.
② Employees shall not be employed by other companies or individuals while employed by the Company.
③ Employees shall not engage in other activities that interfere with their primary duties, whether during or outside working hours.

Article 19 (Principles of Business Execution)

① Employees shall perform their duties with integrity and establish procedures to ensure transparency and fairness.
② Employees shall not omit, distort, or conceal information and must accurately record and report all business activities.
③ Employees shall not violate principles through improper sales recognition, abnormal credit operations, or non-compliance with quality and safety processes.

Article 20 (Expense Management)

① Employees shall use Company budgets solely for their intended purposes and obtain prior approval for excess spending.
② Employees shall not dispose of Company assets arbitrarily to secure departmental funds.
③ Employees shall receive business-related expenses only through registered personal bank accounts and shall not use personal accounts for other purposes.

Article 21 (Reporting of External Lectures and Activities)

① Employees must obtain prior approval before participating in external lectures, seminars, evaluations, or advisory roles.
② Income from such activities must be reported in advance and remain within standard compensation limits.
③ Presentation materials must comply with information security regulations and be reviewed by the information security officer.

Article 22 (Information Security)

① Employees shall not access unauthorized information or facilities, nor leak or misuse Company information.
② Employees shall not disclose or use Company information after resignation.
③ Employees shall not exchange information with competitors without prior approval.
④ Employees shall comply with all personal data protection laws and regulations.

Article 23 (Duty of Compliance and Responsibility)

① Employees shall comply with this Code of Ethical Conduct and bear responsibility for any violations.
② Managers are responsible for encouraging compliance and supervising their teams.

Article 24 (Disciplinary Measures)

Violations of this Code may be referred to the Personnel Committee and subject to disciplinary action in accordance with Company regulations.

Article 25 (Consultation and Interpretation)

For matters requiring interpretation, the Audit Department shall consult the Compliance Management Team of the Future Strategy Office.

Article 26 (Investigation of Violations)

① The Audit Department shall promptly investigate reported violations.
② Employees shall cooperate fully with investigations.
③ Corrective and preventive measures shall be implemented as necessary.

Article 27 (Reporting Obligations and Procedures)

① Employees must report any violation of this Code immediately.
② The Company shall take measures to protect whistleblowers.
③ The confidentiality of whistleblowers shall be strictly maintained, and no disadvantage shall result from reporting. False reports made with malicious intent may result in disciplinary action.