Philosophy & Business Policy, Code of Conduct

1. To the society
Being conscious of obligations as corporate citizens and recognizing that all officers and employees are the entities that realize the policy of the Company, we will actively fulfill our responsibilities as an entity to the country and the community.

(1) Contribution to the society
We will actively perform social contribution activities as a good corporate citizen and contribute to the vitalization of the community, and the development of safe, comfortable and sustainable airport infrastructure through the construction, management and operation, etc. of passenger terminals that are of highly public nature, and the realization of a barrier-free society, etc.

(2) Respect for human rights
We will respect human rights throughout its business activities, including prohibition of discrimination based on gender, age, nationality, race, ethnicity, religion, social status, disability, sexual orientation and gender identity, etc., prohibition of forced labor and child labor, prohibition of harassment, and ensuring an appropriate working environment.

(3) Consideration for global environment
We will comply with the environment-related laws and actively work on the conservation and protection of the global environment through the measures against climate change, effective use of limited resources, prevention of environmental pollution and consideration for biodiversity, etc.

(4) Co-existence and co-prosperity with community
We will strive to be in harmony with the community for their development and achieve mutual development of us and the community.

(5) Disclosure of corporate information
We will ensure active communication with the society and disclose the corporate information timely in an active and fair manner.

2. To our customers
We will work on the improvement of customer satisfaction at all times in order to realize “Customer First” as our business policy.

(1) Pursuit of customer satisfaction
We will aim at the maximum level of satisfaction at all times so that customers who use the airport terminal buildings will use them again.

(2) Compliance with consumer-related laws
When entering into contracts with customers, we will conduct transactions in a clear and fair manner. We will not induce customers using a deceptive method or unreasonably expensive giveaways in the course of conducting representations, advertisements, or campaigns.

(3) Management of customer information
We will strictly manage the personal information of customers. We will not use it for any purpose other than intended purposes or cause leakage or unauthorized use of the information in accordance with the laws related to personal information protection and the privacy policy.

(4) Handling of complaints
We will strive to deal with consultations and complaints by customers in a prompt and sincere manner.

3. To our regular clients, business partners, and competitors
We will abolish empty formalities with regular clients, subcontractor companies or competitors and devote ourselves to the development of fair transactions and competitions.

(1) Relations with regular clients and subcontractor companies

1. We will comply with all relevant laws and codes and sound business practice and act based on a high standard of ethics.
2. We will provide entertainment or gifts appropriately in accordance with the prescribed standards for approval and expense processing procedures and to the extent deemed reasonable in light of social norms only in cases where necessary for corporate activities.
3. We will strive to establish a sustainable value chain together with regular clients and subcontractor companies.

(2) Relations with competitors
We will ensure fair transactions and will not engage in unfair acts, such as defamation of competitors and inappropriate comparative advertising. If such act of any other company occurs, we will take resolute measures and responses.

(3) Management of customer or industry information
We will exercise due care in handling any confidential information of regular clients and industry members that is obtained in the course of our duties (including personal information) and maintain such information in confidence. We will not obtain such information by fraudulent means or use such information for any purpose other than intended purposes.

4. To our shareholders and investors
We will strive to earn an appropriate evaluation in capital markets and maximize the interests of shareholders through timely and highly transparent information disclosure and active IR activities.

(1) Fair and transparent accounting reporting
We will make fair and transparent report on business results by way of accounting processing in compliance with accounting principles and companies act, etc. as well as ensure the reliability of accounting audit.

(2) Information disclosure
We will comply with the relevant laws and standards, etc. and disclose the corporate information appropriately.

(3) Active IR activities
We will provide, in an active and fair manner, not only the information required to be disclosed under the laws and regulations but also the information necessary and sufficient for gaining appropriate evaluation in capital markets and for enabling shareholders and investors to make adequate judgment.

5. To politics and administration
We will maintain sound and normal relations with political groups and public officials and will not engage in any illegal acts or even misleading acts.

(1) Maintenance of sound and normal relations with politics

1. We will make a judgment, on a case by case basis, about the propriety of the request for donation to or purchase of party tickets of political parties or political fund organizations in accordance with the relevant laws and internal rules, and take appropriate actions.
2. In the course of election campaigns, we will neither commit illegal acts, such as provision of money, articles, or wining or dining, nor cooperate with political candidates in illegal acts.
3. In order to ensure the freedom of thought and belief, we will not engage in any act of forcing, as an organization, individuals to express their support for a specific candidate in election.

(2) Prohibition of giving of bribe to public officials

1. We will not engage in any act of giving a bribe to public officials or deemed public officials, etc. or any act that may be misleading as such.
2. We will not engage in any act of giving a bribe to public officials of foreign countries or any act that may be misleading as such.

(3) Accurate and transparent tax reporting

1. We will comply with the tax-related laws and contribute to the sound development of society through adequate tax reporting and payment.
2. In compliance with the tax-related laws, we will utilize the preferential taxation system, etc. appropriately and strive to make taxation costs more proper. In addition, we will not engage in any act that is deemed, in light of social norms, to constitute a tax avoidance that is contrary to the purport of tax-related laws.

6. To antisocial forces
We will ban any relations with antisocial forces that threaten the civil society.

(1) Refusal of grant of benefits

1. We will not grant any benefits to antisocial forces.

(2) Sharing of information

1. We will share information about antisocial forces within the group and develop the system for reporting and taking actions.

(3) Cooperation with relevant bodies

1. We will strive to eliminate antisocial forces in cooperation with the industry members and the society and in close collaboration with police and other relevant administrative bodies.

7. Relations between the Company and its officers and employees
The Company and its officers and employees will establish a relationship of mutual trust through sincerely fulfilling their mutual obligations and responsibilities.

(1) Obligations of the Company toward its officers and employees

1. Elimination of discrimination and harassment
   1. We will eliminate discrimination based on gender, age, nationality, race, ethnicity, religion, social status, disability, sexual orientation, gender identity, etc. We will never allow workplace bullying, sexual harassment, pregnancy discrimination or any other harassment.
2. Improvement of wellbeing
   1. We will strive to maintain and improve an employee-friendly work environment, taking the safety, health, and mental health into account.
   2. We will strive to establish the environment that provides job satisfaction to various human capital.
   3. We will provide the opportunity for skill development so that various human capital can make full use of their abilities and cultivate their potentials.
   4. We will strive to enhance various welfare benefit systems.
   5. We will take and support measures necessary for the maintenance and promotion of health of officers and employees.
3. Confidentiality of personal information of officers and employees
   1. Taking privacy of officers and employees into consideration, we will disclose the personal information of officers and employees only to the departments and management staff on a need to know basis and will not engage in any act of providing such information unnecessarily outside the Company as well as within the Company.
   2. We ensure that we will protect whistleblowers who report to the compliance information desk and that whistleblowers will not treated disadvantageously on grounds of whistleblowing.

(2) Obligations of officers and employees toward the Company

1. Duty of loyalty
   1. In order to realize the management philosophy, we will fulfill our obligations faithfully in compliance with not only laws but also the Rules of Employment, this Code of Conduct and other internal rules. We will not abuse the authority given to us.
   2. Except in cases where required for business activities and approved by the Company, we will not engage in political and religious activities in the capacity of a position at the Company or of an employee of the Company.
2. Prohibition of acts of conflict of interest and mixing of business and personal affairs
   1. We will not engage in any act of conflict of interest with the Company or act of mixing business and personal affairs, such as personal use of company assets
3. Appropriate procedures for application and approval of expenses
   1. We will appropriately disburse investments or expenses in accordance with the prescribed standards for internal approval and expense processing procedures and appropriately perform accounting and tax processing in accordance with the relevant laws, accounting standards, and internal rules.
4. Information management (confidential information and insider information)
   1. Whether during the period of employment or after retirement,, we will exercise due care in managing any confidential information of the Company or any third party that we have learned in the course of our duties and will not use such information without due authorization or leak such information to any third party.
   2. We will comply with the regulation on insider trading and will not engage in unjust transactions of shares, etc. utilizing insider information that we have learned in the course of our duties or leak such information to any third party.
5. Compliance with laws and regulations and prohibition of acts that damage the honor or credibility of the Company
   1. In our private life, we will maintain the dignity as sound working members of society and behave in a moderate manner. Not to mention compliance with laws, we will not engage in any speech or behavior that results in damaging the honor or credibility of the Company.