Governance and public policy

We understand that our actions as an organization have far-reaching implications beyond our walls. With a sharp focus on transparency, accountability, and compliance, we ensure that our corporate governance practices align seamlessly with our dedication to shaping positive outcomes. Our robust policies and governance framework help us maintain the highest standards of integrity and empower our business and the communities we serve.

About governance and policies

1. Basic Approach to Corporate Governance

Topcon has established the TOPCON Corporate Governance Guidelines in pursuit of the sustainable growth and medium- to long-term enhancement of the corporate value of the Topcon Group (Topcon, Topcon Healthcare, and Topcon Positioning Systems) hereinafter referred to as the “Group”), comprising the Company and its affiliated companies, based on TOPCON WAY, a set of the fundamental values, evaluation standards, and basic principles of conduct to be shared by directors, corporate auditors, officers and employees of the Group in its aim to achieve effective corporate governance.

2. Corporate Governance Structure

1. Corporate organization

Topcon has adopted the “company with a Board of Corporate Auditors” as its corporate structure under the Companies Act.

The Board of Directors shall nominate multiple independent outside directors to enhance supervisory functions by incorporating outside opinions into management.

The Board of Corporate Auditors and Corporate Audit Division (internal audit department) discuss each of their audit plans and policies, etc., in advance. They work in mutual cooperation by regularly sharing information throughout the fiscal year to increase the efficiency and effectiveness of the operations of the Corporate Auditors.

As an advisory body to the Board of Directors, the Company shall establish a Nomination and Compensation Advisory Committee, which shall appoint an independent outside director as chairperson and shall be comprised of a majority of independent outside directors.

2. Board of Directors

ⅰ）Roles and responsibilities of the Board of Directors

The Board of Directors recognizes its fiduciary responsibility to shareholders towards the sustainable growth and medium- to long-term enhancement of the corporate value of the Group. Based on such recognition, the Board of Directors works to achieve “improved management efficiency” in addition to “maintaining management soundness” and “ensuring transparency in management,” as well as to fulfill its responsibilities towards all stakeholders in the management of the Group.

To fulfill the responsibilities as stated above, the Board of Directors conducts, from an independent and objective standpoint, the assessment of the performance, appropriate development, and implementation of internal control systems and risk management systems, as well as the supervision of the overall business management of the Company.

The Board of Directors makes decisions on matters provided for in laws and regulations and the Articles of Incorporation, as well as on important matters relating to business management. The Board of Directors has adopted the “Executive Officer System” as a business execution system based on its decision-making and delegates day-to-day business execution to Executive Officers. Executive Officers are appointed by a resolution of the Board of Directors, taking into account their level of knowledge and experience as required in the relevant business field of the Company.

The Board of Directors establishes a system to respond to cases where a Corporate Auditor or the Accounting Auditor discovers misconduct and requests appropriate measures or identifies any inadequacies or problems.

The Board of Directors analyzes and evaluates the effectiveness of the Board of Directors and discloses a summary of the results.

ⅱ) Composition of the Board of Directors

The Company's Board of Directors consists of ten directors (including five outside directors).

The Company ensures the system to supervise the operation of the Company by appointing more than one Independent Outside Director, who express their opinions from an independent and objective standpoint at the meetings of the Board of Directors.

The Board of Directors is composed of Directors who have different backgrounds in terms of expertise and experience and maintains the proper number of Directors so that the Board of Directors can effectively exercise its decision-making and supervisory functions.

ⅲ) Internal control systems

In order to ensure smooth business operations under appropriate control, the Board of Directors sets forth basic policies regarding the development of internal control systems and supervises the establishment of the Group’s structure and the status of implementation thereof to ensure compliance, appropriate financial reporting, and risk management.

The Company has established the Corporate Audit Division as an internal audit department to validate the appropriateness and effectiveness of internal management systems and maintains a system that facilitates the timely reporting of any significant matters to the Board of Directors, etc.

The Company has established the Basic Rules for Risk and Compliance for the development of a risk management system capable of responding to any risk that arises within the Group in a timely and appropriate manner, depending on the nature of the risk.

The competing transactions of Directors, transactions between Directors and the Company, and transactions that involve conflicts of interest of both parties shall be matters to be approved by the Board of Directors.

3. Board of Corporate Auditors

ⅰ）Roles and responsibilities of the Board of Corporate Auditors

The Board of Corporate Auditors recognizes the responsibility to shareholders as the trustees of shareholder assets. The Board acts to ensure corporate stability towards achieving sustainable Group growth and medium- to long-term improvements towards our corporate value to generate shared profit with our shareholders.

The Board of Corporate Auditors works with Outside Directors and the internal audit department

ⅱ）Structure of the Board of Corporate Auditors

To ensure transparency and fairness, Independent Outside Auditors comprise the majority of the Topcon Board of Corporate Auditors.

The Board of Corporate Auditors of the Company consists of four Corporate Auditors (including two outside Corporate Auditors).

Persons with appropriate experience and competency are nominated to serve as Corporate Auditors.

The Board of Corporate Auditors nominates one or more members with knowledge of finance, accounting, and legal affairs, particularly persons with expertise in finance and accounting, necessary to ensure the functions of the Board of Corporate Auditors.

ⅲ）Relationships with the Accounting Auditor and internal audit department

The Board of Corporate Auditors has established a system to conduct sufficient and appropriate audits in collaboration with the Accounting Auditor and the internal audit department.

The Board of Corporate Auditors evaluates the independence and expertise of the Accounting Auditor by formulating assessment and appointment standards of the Accounting Auditor for the purpose of appropriate selection and assessment.

The Board of Corporate Auditors establishes a system to respond to cases where the Accounting Auditor or internal audit department discovers misconduct and requests appropriate measures or identifies any inadequacies or problems.

4. Accounting Auditor

The Accounting Auditor assumes an important role in securing the reliability of the financial information of the Group and bears responsibility to shareholders and investors.

The Accounting Auditor ensures a system under which it can conduct appropriate audits in collaboration with the Board of Corporate Auditors.

The Accounting Auditor ensures independence and expertise.

The Accounting Auditor complies with standards on quality control for audits necessary to conduct accounting audits appropriately.

5. Nomination and Compensation Advisory Committee

The Company has established the Nomination and Compensation Advisory Committee, which is independent of the Board of Directors, for the purpose of ensuring objectivity and transparency in the selection of candidates for President and Director and in the handling of compensation for Directors.

An independent outside director chairs the Nomination and Compensation Advisory Committee, and the majority of its members are independent outside directors.

The Nomination and Compensation Advisory Committee makes recommendations to the Board of Directors in response to the Board of Directors’ inquiries.

6. Internal audit department, etc.

The Company has established the Corporate Audit Division as an internal audit department to validate the appropriateness and effectiveness of internal management systems, as follows:

The Corporate Audit Division aims to contribute to enhancing the corporate governance and risk management of the Group. The Corporate Audit Division is responsible for the internal audit process and develops a system under which the Corporate Audit Division validates the appropriateness and effectiveness of internal management systems such as compliance, and reports to the Board of Directors, the Board of Corporate Auditors, and Representative Director President in a timely manner if any significant issue is discovered.

The Corporate Audit Division conducts group company audits in collaboration with Corporate Auditors and the Accounting Auditor to ensure the appropriate business conduct of the entire Group.

With respect to whistleblowing matters, the Corporate Audit Division shall contribute to the early discovery of risk information and conduct measures regarding the nature of the whistleblowing matter in a swift and appropriate manner.

7. Directors and Corporate Auditors

ⅰ）Directors

Directors recognize their fiduciary responsibility to shareholders and execute their duties as Directors toward the sustainable growth and medium- to long-term enhancement of corporate value.

As members of the Board of Directors, directors supervise the execution of business operations by Executive Directors and Executive Officers.

Directors collect sufficient information to execute their duties while requesting explanations on various matters, proactively expressing opinions, and holding open and constructive discussions at meetings of the Board of Directors.

Directors proactively collect information for appropriately fulfilling their roles and responsibilities and, if necessary, seek the advice of external experts at the expense of the Company.

As an executive incentive for Directors (excluding Outside Directors), the Company adopts medium- to long-term performance-linked compensation and restricted stock compensation to achieve the Group’s sustainable growth and enhance corporate value over the medium to long term (excluding outside directors).

ⅱ）Corporate Auditors

Corporate Auditors recognize their fiduciary responsibility to shareholders and execute their duties as Corporate Auditors, ensuring corporate soundness towards sustainable growth and medium- to long-term enhancement of corporate value.

In accordance with policies and assigned duties set forth by the Board of Corporate Auditors, Corporate Auditors conduct audits on the status of the execution of duties by the Directors and Executive Officers, etc., of the Company through the following activities: attending important meetings of the Company, including the meetings of the Board of Directors; receiving reports from Directors, etc. on the status of their execution of duties; receiving materials and information on related matters; and collaborating with the internal audit department and the Accounting Auditor.

Corporate Auditors audit the decision-making by the Board of Directors and the status of the development and implementation of internal control systems.

Corporate Auditors proactively collect information for appropriately fulfilling their roles and responsibilities and, if necessary, seek the advice of external experts at the expense of the Company.

ⅲ）Independent Outside Directors and Independent Outside Corporate Auditors

Independent Outside Directors and Independent Outside Corporate Auditors supervise the execution of business operations, provide advice for the sustainable growth and medium- to long-term enhancement of corporate value, and manage conflicts of interest while conveying the opinions of stakeholders, including minority shareholders, to the Board of Directors.

There are five independent outside directors and two independent outside corporate auditors.

Independent Outside Directors share information regarding matters related to the business and corporate governance of the Group and exchange opinions with each Director, Executive Officer, and Corporate Auditor.

The Company appoints Outside Directors and Outside Corporate Auditors who meet the criteria for independence specified by financial instruments exchanges.

Independent Outside Directors and Independent Outside Corporate Auditors work to exchange information and share perspectives based on an independent and objective standpoint by holding regular meetings.

iv) Support System

The Company has established an effective and sufficient support system for directors and corporate auditors to fulfill their roles and responsibilities as follows

The Company operates its Board of Directors meetings as follows to enable sufficient discussion at Board of Directors meetings.

(1) The Company prepares an annual schedule of Board of Directors meetings and makes an annual plan of items to be discussed.

(2) Appropriate deliberation time is set aside for sufficient discussion at Board of Directors meetings.

(3) Materials related to matters to be discussed at Board of Directors meetings are distributed well in advance.

(4) In addition to the above, information necessary for directors to make decisions and for corporate auditors to perform their duties is provided as needed.

In addition to the above, the Company provides information necessary for directors to make decisions and corporate auditors to perform their duties as needed.
The Company appoints assistants as necessary to assist the statutory auditors in their duties and support other activities of the statutory auditors, provides corporate information requested by the statutory auditors, and coordinates internal collaboration.
The Company proactively provides outside directors and outside corporate auditors with information necessary for the execution of their duties when requested.
The Company secures budgets deemed necessary for the execution of duties by Directors and Corporate Auditors.

v）Training policies

The Company provides information and knowledge on business activities necessary for Directors and Corporate Auditors to fulfill their roles and responsibilities appropriately in accordance with the following provisions.

When Directors or Corporate Auditors are newly appointed, the Company provides training regarding laws and regulations related to the business of the Group and the Group’s corporate governance and provides, on an ongoing basis, such training even after assuming office as Directors and Corporate Auditors.

In addition to the aforementioned, when Outside Directors and Outside Corporate Auditors are newly appointed, the Company provides the information regarding the Group’s business and overall organization, etc., and also provides, on an ongoing basis, the necessary information regarding the Group’s business strategies and issues to be addressed, etc., even after assuming office.

Topcon will prioritize the safety and relief of employees and their families.
Topcon will fulfill the responsibility for the supply of the goods to customers.
Topcon will support the restoration of the region and customers.
Topcon will aim at an early restoration of business and minimize the adverse effects on management.

Chapter 1. ABOUT THE CODE OF CONDUCT

1. What is the Topcon Global Code of Conduct?

This Topcon Global Code of Conduct (this “Code”) stipulates the standards of conduct of the Topcon Group regarding compliance with laws, regulations, internal rules, and social ethics in carrying out our business. It is our statement about how directors, officers, and employees of the Topcon Group should behave.

2. Who is this Code Applied to?

This Code applies to Topcon Corporation and its direct and indirect subsidiaries (collectively the “Topcon Group,” and independently a “Company”) and all directors, officers, and employees of the Topcon Group (“Employee(s),” “You” or “We”).

3. Local Code of Conduct

To address local laws, regulations, official notifications, and guidelines in each relevant country or region, each company may adopt its own local code to supplement this code. However, no provision in the local code shall conflict with or be less stringent than this code.

4. We Require Understanding of this code

Operating a business with ethics and integrity and being a good corporate citizen is critical to maintaining the Topcon Group’s competitive strength and the key to achieving the Topcon Group’s management vision.

Employees are required to read, understand, and comply with this code, which includes that You must comply not only with the letter of this code but also with its spirit. Employees must also comply with all laws, regulations, and/or internal rules related to our business activities.

This code cannot cover all situations, laws, or regulations. We must use good judgment and common sense in conducting ourselves in the workplace and business and making decisions in our daily work.

If you are a manager, you must also:

Take initiative in observing this code,
Act as a role model for other employees
Make sure that your subordinates receive training on this code and
Have them understand this code’s requirements

5. Contact Information

If you have any questions, contact the Legal Department of Topcon Corporation or that of Topcon America Corporation.

6. We Require Reporting of Suspected Violations

(1) We Require Reporting of Suspected Violations

Employees must immediately report any violation or suspected violation of this code (“violations”). Various reporting channels are available, including:

Your direct supervisor.
Any supervisor in your reporting chain.
Hotline (if available in your location).

(2) We Promptly Investigate and Take Action on All Reports

Any company that receives such report or information will promptly investigate all violations and take appropriate action to address violations and remediate any resulting adverse effects. Each employee has a duty to cooperate with these investigations in good faith and not to do anything to interfere with them.

(3) We Prohibit Retaliation

The Topcon Group strictly prohibits retaliation (including but not limited to disciplinary action, disadvantageous evaluation or changing workplace, and restriction on promotion or increase in salary) against anyone who makes a good faith report of or provides information regarding any violations because of making such report or provision of information.

(4) Employees must not make a report which includes false statements or make a report for the purpose of slandering individuals.

7. Countermeasures against Violation of this Code

Any conduct in violation of this Code will be subject to disciplinary action, including termination of employment, depending on the circumstances.

Chapter 2. BUSINESS WITH INTEGRITY AND FAIRNESS

1. Building Our products – We Design and Manufacture Safe, High-Quality Products that Meet Customer Needs

(1) The Topcon Group is committed to “Customer Orientation” and “Quality First” and to providing products to our customers that are safe, of the highest quality, and that maximize customer satisfaction. The Topcon Group seeks leadership in all of the markets we serve. Leadership requires superior products, a constant focus on quality, and maintaining the highest reputation for competence, quality, and integrity.

(2) All the processes of development, design, manufacture, procurement, sales, and after-sales services are of great importance in providing safe and high-quality products. Regardless of the department to which we belong, each of us must strive to upgrade the quality of our products and establish, maintain, and improve the quality management system.

(3) We will comply with all laws, regulations, official notifications, guidelines (collectively “Laws” in this section), standards of our products, contracts, and internal rules that relate to our business. We will be knowledgeable about and comply with the medical device laws or related laws in each country and/or region in connection with the manufacture and sale of medical devices.

(4) If we become aware of any incident related to the safety and quality of our products and services, the Topcon Group will immediately investigate it, share information, and take appropriate action. In this case, the Topcon Group will also investigate the root cause and make efforts to prevent a recurrence.

2. Selling Our Products

2.1. We Respect Our Customers

The Topcon Group is committed to responding to various customer needs with products and services that maximize “Customer Satisfaction.” Because of our respect for our customers, we will use customer feedback and improve product performance and services to maximize customer satisfaction.

2.2. We Act Fairly in Marketing and Sales

The Topcon Group will market and sell its products and services in a fair, truthful, and ethical manner.
When engaging in sales and marketing activities, we:

Will recognize that We are representing the Topcon Group to the customers, serve all customers fairly and equally, and make every transaction in fair and appropriate conditions with our customers.
Will not misrepresent Topcon’s products or services.
Will not slander our competitors or their products.
Will compete vigorously and fairly, observing all applicable laws relevant to free and fair competition, including the Japanese Anti-Monopoly Act and the antitrust and free trade laws of the U.S. and the E.U.
Will observe all applicable laws, regulations, and internal rules of each relevant country or region where the Topcon Group conducts its business.
Will obtain, manage, and use information on the market and customers in a proper way.

2.3. We Act with Integrity in Government Transactions

The Topcon Group will operate with the highest ethical standards in conducting business with various government entities (including local governments) (the “Government”), including complying with all applicable laws and regulations and with the terms of any Government contract.
When conducting business with the Government, you:

Must not provide false information (including false estimates of contract prices).
Must not charge incorrect or unauthorized costs or fees.
Must not engage in improper agreements with competitors (such as those on bidding opportunities or bid prices) that are prohibited under any competition laws or regulations.
Must not make improper payments to any Government or its officials, such as improper rewards, entertainments, gifts, donations, or gratuities.
Must not disclose, leak, or use confidential information received from the Government or its officials in such a manner as to breach any confidentiality obligation.
Must not hire Government officials in a manner where the official has the ability to influence decision-making about Government contracts in violation of applicable laws or Government regulations.

These are just examples. You are responsible for understanding the details of prohibited conduct under applicable laws and regulations in the country or region where you are involved in the business.

2.4. We Advertise Fairly and Accurately

The Topcon Group will advertise to raise public recognition of the brands of the Topcon Group and establish the image of the Topcon Group as a “good corporate citizen” on a global basis.
In doing so, we will advertise in a positive manner and follow all applicable laws and regulations. Especially the Topcon Group:

Will never advertise by slandering or libeling others or other’s products.
Will not present false or misleading advertisements.
Will not make references to politics or religion in its advertising. Also, it will not make advertisements in a manner which are likely to lead to racial discrimination or impairment of the personal dignity of any group or individual.

3. Procurement

The Topcon Group values its suppliers, who make significant contributions to the success of our business. The Topcon Group will deal with its suppliers with honesty and integrity and procure the necessary materials (including services) at the appropriate quality, price, and delivery period under fair trade relationships.
In procurement activities:

We will observe all applicable laws, regulations, internal rules, and sound customs of trade.
We will promote “green procurement” for the manufacturing of environment-friendly products. We put a priority on items that produce lower environmental impacts.
We will provide suppliers with equal opportunities for competition and procure necessary materials and services based on a comprehensive and fair evaluation from the viewpoints of quality, price, delivery period, after-sales service, stable supply, and consideration for the environment.

4. Engineering Ethics

Engineering has a vital impact on society and people. Accordingly, engineers in the Topcon Group are expected to:

Contribute to the health, welfare, and safety of the public with their professional competence.
Engage in their work based on scientific facts from an objective perspective with the highest standards of impartiality, integrity, and honesty. Be sensitive to changes in the laws. Use common sense in carrying out business responsibilities.
Train successors and pass technology and know-how onto the next generation.

5. We Comply with Export Controls

(1) The Topcon Group is a global company. We sell and develop our products throughout the world. All governments control and restrict international trade for certain goods, services, and data. Many governments impose embargoes on other countries and sometimes on certain people and organizations. The Topcon Group will not engage in any transaction that may undermine the maintenance and improvement of international peace and safety.

(2) For this purpose, Employees involved in relevant transactions must understand and follow all applicable export control laws and regulations in the countries where the Topcon Group conducts its business, including, but not limited to, those of Japan and the United States of America.

(3) The Topcon Group has extensive export control compliance programs to ensure compliance with the above export control laws and regulations. Employees must be familiar with and abide by these programs.

6. We Comply with Competition Laws

Competition laws are designed to promote free and fair business competition. We will comply with all applicable laws and regulations in each country and region designed to safeguard fair competition.

Agreements with our competitors, whether written or spoken, on the following topics are prohibited:

prices;
bidding opportunities or bid price;
production or sales quantity or amount;
share allocation;
limiting or splitting customers or sales territories;
limiting production capacity or technology.

Never put yourself into a situation where you appear to be discussing these issues with a competitor.

Also, competition laws usually prohibit or restrict certain types of resale price maintenance. You must understand and follow these laws.

7. Anti-Corruption

7.1. We Prohibit Improper Payments

The Topcon Group will not offer or give bribes or any other improper interests in violation of laws, regulations, and/or sound trade customs.
You must understand that bribes to government officials and employees in private enterprises are prohibited in certain countries. You must understand and comply with all applicable laws and regulations of the country or region in which you are involved in business.

What Is a Bribe?
In this Code, the term “Bribe” means anything of value offered or given for the purpose of gaining improper commercial interests or in consideration of such improper interests and offered or given to the following persons:

government officials, foreign government officials (including employees of state-owned enterprises and international organizations, also including ex-officials);
politicians, candidates of politicians, political parties, and employees thereof;
customers (legal or natural persons).

A bribe does not have to be cash. It can include rewards, entertainment, gifts, donations, gratuities, and any other type of benefits. Even items of minimal value may constitute a wrongful bribe.

When using an intermediary (such as an agent) in our business, we must ensure that they will not engage in the corrupt practices designated above and clearly agree in advance on the scope of the services and the amount of compensation and ensure that these conditions are reasonable.

7.2. We Do Not Demand or Accept Gifts and Entertainment as Business Inducements

Employees must not demand or accept any personal benefits in connection with his/her job.
However, receiving gifts and entertainment from customers, suppliers, or contractors is permissible only if it is inexpensive in value and customary in nature and is consistent with applicable laws, regulations, and sound customs of trade and only if it would not affect a particular business decision of the Topcon Group.
Any gifts or entertainment that are excessive or seem unreasonable must be refused.

7.3. We Do Not Accept Money Laundering and Participate in the Financing of Terrorism

The Topcon Group is firmly committed to full compliance with applicable anti-money laundering and counter-terrorism laws and regulations. We conduct business only with reputable third parties who engage in legitimate business activities. This also applies to our relations with trading partners such as suppliers, vendors, and other sub-contractors.

Employees must not participate in any activity aimed at laundering money or financing terrorism. In addition, you must not provide assistance to any person or organization trying to benefit from the proceeds of a criminal act or illegal activity or controlling funds invested for the benefit of a terrorist organization.

Chapter 3. PROTECTING THE COMPANY’S ASSETS AND INFORMATION

1. We Protect Company Assets

We must protect the Topcon Group’s assets (whether tangible or intangible) and use them solely for the purpose of carrying out our duties at the Topcon Group. Using the Topcon Group’s assets for personal benefit (for his/her own or third party) is prohibited.

2. We Protect Confidential Information

Information is among the most valuable of the Topcon Group’s assets and must be protected from unauthorized disclosure and inappropriate use.

What is Confidential Information?
In this Code, the term “Confidential Information” includes any type of information, whether tangible or intangible, regardless of who creates or owns it, related to the Topcon Group, its business practices or customers, suppliers, and other business partners, disclosure or leakage of which to a third party would cause disadvantage to the business activities or even to the reputations of the Topcon Group or those third parties.

Your Confidentiality Obligations
You must take great care to properly control Confidential Information, and you must:

During and after employment, do not disclose or leak Confidential Information you learn during employment.
During and after employment, do not use the Confidential Information for personal benefit, for a third party’s benefit, for any other unauthorized purpose, or in any other improper way.
Respect the valuable information of others. You must not obtain it improperly or disclose or use it in an improper manner or for an improper purpose.
Never use in your job, bring to the Topcon Group, or disclose to other employees in the Topcon Group any Confidential Information that belongs to others which was obtained prior to employment with the Topcon Group.

3. We Protect Intellectual Property

Among the Topcon Group’s most valuable assets is its Intellectual Property. Intellectual Property is essentially the work product created by employees in the course of research, development, and other business activities, which the laws and practices protect and give value to. The Topcon Group will maximize the value of its Intellectual Property by effectively using relevant laws and following good business practices.

What is Intellectual Property?
In this Code, the term “Intellectual Property” includes patents, model utilities, designs, trademarks, copyrights, layout designs of semiconductors, trade secrets, and other similar rights.

To the extent permitted by applicable laws and regulations, all inventions, creations, copyrightable works, designs, and layout designs of semiconductors, as well as rights related to them (including application rights) created by Employees, belong to the Company. Employees must understand and follow internal and Governmental rules to protect the Intellectual Property rights of the Topcon Group.

Respecting the IP Of Others:
The Topcon Group will respect the Intellectual Property of others. You must not improperly use or infringe upon the Intellectual Property of others.

4. We Protect Personal Information

The Topcon Group will properly protect Personal Information in business activities.

What is Personal Information?
In this Code, the term “Personal Information” means information in relation to customers, officers, and employees of customers, suppliers and business partners, applicants, Employees, and other individuals that are handled by employees in business activities and that can be used to identify a specific individual.

We will collect, manage, and use Personal Information in a proper and fair way and in compliance with all applicable laws and regulations regarding the protection of Personal Information in countries or regions where the Topcon Group does business.

5. Use of Social Media

Words and behavior on social media may affect the reputation and brand awareness of the Topcon Group and may be viewed by customers, suppliers, business partners, the counterparties of lawsuits, or persons concerned with such parties.
You must carefully review in advance what you will post on social media, which may be related to the Topcon Group, and clarify that it is just a personal view.

Chapter 4. RELATIONSHIP WITH EMPLOYEES

1. We Respect Human Rights, Free from Unlawful Discrimination and Harassment

(1) The Topcon Group is a global company with a diverse workforce comprised of people from a wide variety of backgrounds, origins, experiences, and cultures. We will recognize diverse values, respect fundamental human rights and the personalities and characters of individuals in light of human dignity, and seek to maintain a workplace where all individuals are respected.

(2) The Topcon Group is committed to providing equal opportunity in employment and business generally. We will not tolerate unlawful discrimination in the workplace by or against any of our employees, contractors, or representatives.
All coworkers, job applicants, customers, and suppliers are to be treated respectfully and on an equal basis without regard to race, color, religion, sex, national origin, age, veteran status, physical or mental disability, sexual orientation, gender identity or other status protected by applicable law.

As part of our commitment to providing Topcon Employees with a safe, secure work environment, the Topcon Group will also prohibit unlawful harassment based on the above-protected characteristics. We will not allow:

Conduct by Employees or others, including suppliers, salespeople, customers, and visitors, directed at an individual due to such personal characteristics that are intimidating, insulting, abusive, offensive, or hostile;
Sexual harassment, which consists of unwelcome sexual comments, sexual advances, or requests for sexual favors;
These types of prohibited conduct are damaging to the Topcon Group and our Employees, disrupt our workplace, and interfere with work performance.

Our commitment to a safe and secure work environment means that We will not tolerate workplace violence or threats of violence. Prohibited conduct includes not only physically violent or abusive conduct but also aggressive, intimidating, or disorderly physical conduct and abusive or threatening language.

(3) The Topcon Group is committed to doing the right thing in the right way and aims to ensure that the highest standards of business ethics, conduct, and integrity are maintained, and we are fully committed to combatting slavery and human trafficking, including in our supply chain. The Topcon Group takes a zero-tolerance approach towards slavery, servitude and forced or compulsory labor, human trafficking, sexual exploitation; removal of organs outside of an authorized medical procedure taking place in a hospital; securing services or other type of benefits by force, threats or deception; or securing services or other type of benefits from children and vulnerable persons, even without the use of force, threats or deception.

2. Development of Topconian Culture

The Topcon Group will treat with respect and develop all those who are focused on the attainment of our management vision, especially those who:

Seek to develop and maintain a high level of expertise and use the expertise to generate business success and profitability.
Act with a sense of universal values, including thinking beyond national borders and respecting cultural diversity.
Demonstrate through actions that they place an importance on collaboration and teamwork.

3. We Maintain an Inclusive Workplace

The Topcon Group will endeavor to provide Employees with equal and fair opportunities to proactively study, grow, implement, and maintain an open, inclusive, and orderly workplace where Employees can maximize their creativity and ability. Employees must perform their duties in their area of competence and within their authority. Employees will seek professionalism through developing knowledge within and outside of their daily work.

4. We Maintain a Safe Workplace

(1) Ensuring a safe work environment is important for employees to maximize their performance and prevent workplace injuries. The Topcon Group will take all necessary measures to ensure and maintain healthy and safe work facilities. Also, the Topcon Group will establish working standards that take into account the safety and health of its employees.

We must put safety first and comply with applicable health and safety laws, regulations, and internal rules.

(2) The Topcon Group will establish an unexpected crisis management system to assure the safety of employees and their families who are on domestic and overseas business trips or overseas assignments (regardless of the countries or regions they stay in) and establish and strengthen safety measures mainly focusing on prevention of incidents and accidents.

5. We Avoid a Conflict of Interest; Private Activities

As a member of the Topcon Group, you have a duty to act to pursue the best interests of the Topcon Group.
To protect Topcon Group’s assets and reputation, you must avoid any business, financial, or other relationship or activity that might create or give the appearance of a conflict of interest or otherwise impair your ability of judgment in carrying out your responsibilities for the Topcon Group.
You must immediately disclose to your manager any circumstances that appear or are likely to appear to create a conflict of interest and must obtain prior approval (if needed) before proceeding with the relevant transaction.

The Topcon Group will support the volunteer and other social activities of Employees.
Employees must conduct any political activities outside the office, outside working hours.

Chapter 5. BEING A GOOD CORPORATE CITIZEN

1. We Act as a Responsible Member of Society

As a member of society, the Topcon Group will strive to contribute to the sustainable development of every society with which We have a relationship. The Topcon Group will proactively expand opportunities to communicate and connect with society and promote activities that contribute to society.

2. Donations, Political Contributions

(1) As a member of society, the Topcon Group will make timely and proper donations as may be necessary for consideration of the social and public good and to contribute to the development and progress of society.

(2) The Topcon Group will not make any political contributions to any politician, party, or candidate directly or indirectly through a distributor or agent except as permitted by laws, regulations, and internal rules. Political contributions are not limited to cash but may also be in the form of loans, entertainment, gifts, commissions, consulting payments, or other forms of payments. The Topcon Group will ensure that our distributors and agents will not make prohibited political contributions on behalf of the Topcon Group.

3. We Care About the Environment

The Topcon Group is committed to promoting environmental conservation in accordance with the following policy. The Topcon Group will:

Comply with all relevant environmental laws and regulations as well as voluntary standards.
Strive to develop and provide environmentally compatible technologies and products.
Actively minimize the use of regulated chemical substances, reduce and recycle waste, and save energy.
Provide training and promote communication so that We all think carefully about environmental protection.
Perform preliminary environmental assessment in each stage of establishing facilities or their restructuring, capital expenditure, planning, development, design, manufacture, delivery, and disposal of our products.
Periodically perform environmental measurement and inspection, retain records of such measures, and allow for proper inspection. If nonconformity is found in such an inspection, the Topcon Group will promptly take appropriate improvement actions.

Chapter 6. COMPANY RECORDS, DISCLOSURES

1. We Present Financial Information Fairly and Accurately

To ensure compliance with applicable laws and regulations, the Topcon Group will properly and completely conduct its account management and financial reporting.

Employees must:

Accurately and in a timely manner, record all accounting information.
Never falsely report transactions or make any false or misleading entry in any book or record.
Only make payments or transfer the Topcon Group funds or assets where the action has been properly authorized and clearly accounted for on the Topcon Group financial records.

The Topcon Group will strive to maintain and improve its accounting management system to ensure that all accounting information is reported accurately and in a timely manner.

2. Public Relations

(1) The Topcon Group is committed to making proper and timely disclosure of its corporate information to ensure that We win the understanding and trust of customers, shareholders, investors, and other stakeholders and to protect the Topcon Group’s name value and reputation.

For this purpose, the Topcon Group will:

Disclose its corporate information in compliance with all applicable laws and regulations.
Make efforts to disclose objective and fair information.

(2) The contact point regarding disclosure of corporate information will be the department in charge of Public Relations. To avoid confusion, employees must obtain prior approval from the department manager in charge of Public Relations if they wish to contact and/or disclose corporate information to mass media, such as newspapers, magazines, or TV stations.

3. We Prevent Insider Trading

In the course of your work for the Topcon Group, you may learn “Inside Information” about the Topcon Group or other companies before it is made public. You must not:

Buy or sell securities using Inside Information or
Disclose Inside Information to others, including colleagues, family members, or friends, without justifiable reason.

What is “Inside Information”?
“Inside information” means any information that, if disclosed, would reasonably be expected to affect investors' decisions in connection with a security investment.

Inside Information includes, for example, the following:

Issuances of shares;
Changes in forecasts of financial results or dividends or similar information;
Commercialization of new products or services;
Acquisition of another company, including through merger;
Business transfers (in whole or in part).

Topcon will put CSR activities in the center of business and work on them to build, share, and implement the sense of values and standards suitable for a global enterprise.
Topcon will, to the extent of our influence, support and implement the rules and regulations that are globally approved regarding Human Rights, Labor Standards, Environment, and/or Anti-Corruption as declared in the Global Compact.
Topcon will make a social contribution voluntarily and actively through the development, production, sales, and services of useful products.
Topcon will promote environmental management by creating environmentally-conscious business processes and providing environmentally-conscious products and services.
Topcon will strive to establish CSR activities in every officer and employee’s daily work and to promote and establish them within global Topcon Group companies.
Topcon will acquire the understanding and confidence of all the stakeholders of Topcon Group companies by providing information actively.

Equal and fair procurement activities
We engage in transparent, equal, and fair procurement activities in new transactions with all business partners.
We make decisions on selecting business partners based on comprehensive and objective evaluations and procedures covering aspects such as certainty in quality, price, deadline, stability in technical standards and administration, and environmental consideration.
Coexistence and co-prosperity
We constantly maintain and encourage trust-based relationships and aim to achieve coexistence and co-prosperity with our business partners through business transactions.
Rules on compliance with laws
We engage in business transactions while complying with laws, social norms, and healthy commercial practices.
Management and protection of information
We never disclose confidential information about our procurement activities with business partners to the outside of our company.
CSR Procurement
Topcon established the ‘Business Partners’ Code of Conduct’ intending to better society and the global environment and realize the sustainable development of the company together with our business partners. We ask all of our business partners to implement this guideline.
Green procurement
We procure items from partners that are implementing conservation activities. We also purchase/use products, parts, materials, and raw materials that produce low environmental load in their lifecycles.
Procurement Activities
Topcon regards “Global procurement, “Purchasing engineering,” and “Green procurement” as three important initiatives. Through briefings and announcements, Topcon communicates with business partners not only Topcon’s basic procurement policy but also Topcon’s view on the Business Partners’ Code of Conduct and Green Procurement Guidelines.

In our commitment to environmental protection and recognizing our responsibility to preserve the global environment as a precious resource for future generations, Topcon Corporation actively collaborates with our suppliers in environmental initiatives.

One significant aspect of our efforts involves encouraging the use of products and services that have minimal environmental impact. To achieve this goal, we prioritize the concept of green procurement. Our aim is to source parts, materials, units, products, secondary materials, and other items we receive ("delivered items") with low environmental footprints. This approach involves promoting environmentally conscious business activities and maintaining awareness of environmental impacts and associated risks.

Topcon’s Activity

1. Procurement from Suppliers promoting environmental preservation activities

Topcon believes it is a self-directed activity for suppliers and will support improvement activities when needed.

During green procurement, Topcon will conduct eco-friendly activities with environment-conscious suppliers, including ISO14001 certification.

Topcon evaluates and assesses suppliers’ activities, such as ISO 14001 certification, green procurement, and environmental preservation activities.

2. Procurement of products/parts/raw materials with less environmental risk

Topcon breaks down procurement items into three basic categories: material for product, procurement for production operation, and office and stationery supplies.

1) Material for product

Purchasing components of Topcon products (including system computers and units) such as parts and materials. Topcon sets points for environmental load reduction in detail and investigates them for using fewer environment load procurement items.

2) Procurement item for production operation

These items include manufacturing equipment, jigs & tools, and consumables such as paint, plating solution, thinner, alcohol, etc. Topcon pursues green procurement per ‘Environmental pre-assessment of water quality, air, noise, vibration, etc.’ and ‘Pre-assessment of chemical substance of new material.’

3) Office and stationery supplies

Writing instruments, stationery, file supplies, and notes are everyday essentials. At Topcon, we consider using eco-friendly office supplies a significant initiative in promoting environmental consciousness among our employees. Consequently, we are actively increasing our sourcing of environmentally friendly products, including those certified with Eco Mark, recycled materials, reusable items, products designed for separate collection, and those free from PVC materials.

We will continuously improve the quality of Topcon’s products and services from the customer’s perspective and build relationships of trust with our customers.

Sign of Trust: ISO9001 Certified

Topcon has obtained ISO9001: 2005, an international standard for quality management systems, for its business field (Surveying instruments and optical unit products for overseas markets) from SGS United Kingdom Ltd. (SGS Japan Inc. in Japan).

This certificate is proof that Topcon’s quality assurance system is globally approved.

Through the certification and maintenance of ISO9001, Topcon Group aims for “customer first” and “quality first” in all its tasks, from development and production to sales and after services, always striving for improvement.

Never satisfied with the status quo, we intend to continue to work on offering even more reliable products and services and meet our commitments as a global company.

Sign of Trust: ISO13485 Certified

Topcon has obtained ISO13485: 2016, an international regulatory requirement for medical devices, for the scope of qualification (design, development, production, and distribution of ophthalmic medical devices) from TÜV SÜD (Germany).

This certificate is proof that Topcon’s quality assurance system for medical devices is globally approved.

Through the certification and maintenance of ISO13485, Topcon Group will do its utmost to improve quality in all stages, from development and design, production, and sales to services, providing highly reliable products to advance our customers’ businesses.

Never satisfied with the status quo, we intend to continue to work on offering even more reliable products and services and meet our commitments as a global company.

Topcon’s materiality and SDGs

What is the UN Global Compact?

The UN Global Compact is a call to companies to align their strategies and operations with ten universal principles related to human rights, labor, environmentand anti-corruption, and take actions that advance societal goals and the implementation of the SDGs.

The Global Compact was first announced by the United Nations Secretary-General Kofi Annan in an address to The World Economic Forum held in Davos, Switzerland in January 1999 and was officially launched at the UN Headquarters in New York in July, 2000. The Global Compact asks companies all around the world to embrace, support and enact the ten principals universally established in regard to human rights, labor standards, the environment and anti-corruption fields.

The Ten Principles

The Ten Principles of the United Nations Global Compact are derived from: the Universal Declaration of Human Rights, the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development, and the United Nations Convention Against Corruption.

Human Rights
Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and Principle 2: make sure that they are not complicit in human rights abuses.
Labour
Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining; Principle 4: the elimination of all forms of forced and compulsory labor; Principle 5: the effective abolition of child labor; and Principle 6: the elimination of discrimination in respect of employment and occupation.
Environment
Principle 7: Businesses should support a precautionary approach to environmental challenges; Principle 8: undertake initiatives to promote greater environmental responsibility; and Principle 9: encourage the development and diffusion of environmentally friendly technologies.
Anti-Corruption
Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.

Source https://unglobalcompact.org/what-is-gc/mission/principles

You can learn more about the UN Global Compact here
https://unglobalcompact.org

Environmental initiatives

We are committed to minimizing our business's environmental impact by adhering to the Topcon Global Code of Conduct. Additionally, we actively work towards reducing the environmental impact through our products and services, with the goal of achieving a sustainable society.

We promote the continued improvement of our environmental management system to enhance the environmental performance of our business activities.
To this end, we consider our environmental efforts one of our most important management tasks and set environmental goals and targets involving all employees, including upper management.
We comply with applicable laws, regulations, acts, guidelines, agreements, and other accepted requirements and apply strict management and control.
1. We strive to reduce our environmental footprint, conserve biodiversity, and prevent pollution. We have set goals to reduce environmental risks. We will offer environmentally friendly products and services with our product lifecycle in consideration.
2. We will increase the level of control of chemical substances and the chemical substances contained in our products.
3. We will focus on reducing waste emissions and strive to enhance the value of waste as a recyclable resource.
4. We will promote efforts to mitigate global warming and strive to reduce greenhouse gas emissions.
We strive to keep our premises and neighborhood clean and beautiful and actively participate in local community activities.
We raise awareness among all employees through environmental education and encourage participation in environmental conservation activities.
We provide systematic and active guidance and support to subsidiaries and affiliates to raise awareness.

As a global corporate group that supplies products worldwide, we are committed to two important environmental objectives: reducing our products' environmental impact and addressing climate change, as outlined below.

Reducing Environmental Impact through Products
We actively encourage energy and resource conservation by minimizing the environmental impact of our products. Additionally, we provide products, technologies, and services that help combat global warming, promote resource efficiency, and support biodiversity conservation. In our manufacturing-focused operations, we are dedicated to recycling and efficiently utilizing waste generated across all aspects of our business, from procurement and development to manufacturing, sales, and services.
Responding to Climate Change
The Topcon Group considers addressing climate change its top environmental priority and is committed to expanding its use of renewable energy. By the end of fiscal year 2030, our goal is to decrease greenhouse gas emissions from our business activities in Japan by 40% compared to the levels in fiscal year 2013.

Through this policy, we strive to reduce greenhouse gas emissions and increase the use of renewable energy power at overseas sites.

Certifications

The Topcon Group has obtained ISO14001 certification, an internationally recognized standard for environmental management systems, especially within manufacturing-oriented companies. In August 2018, the Group successfully completed the transition audit to ISO14001:2015 and has since maintained its certification.

Corporate governance initiatives

Anti-Corruption Policy

As an initiative to combat corruption as stipulated in Principle 10 of the United Nations Global Compact, the Topcon Group prohibits giving out bribes or inappropriate profits in any form that violates laws, regulations, or sound business practices. In addition, we prohibit employees from accepting improper personal benefits or profits in connection to their work or position.

We Prohibit Improper Payments

What is a bribe?
In this Code, the term “Bribe” means anything of value offered or given for the purpose of gaining improper commercial interests or in consideration of such improper interests and offered or given to the following persons:

Government officials, foreign government officials (including employees of state-owned enterprises and international organizations, also including ex-officials);
Politicians, candidates of politicians, political parties, and employees thereof;
Customers (legal or natural persons).

A bribe does not have to be cash. It can include rewards, entertainment, gifts, donations, gratuities, and any other type of benefits. Even items of minimal value may constitute a wrongful bribe.

When using an intermediary (such as an agent) in our business, we must ensure that they will not engage in the corrupt practices designated above and also clearly agree in advance on the scope of the services as well as on the amount of compensation, and ensure that these conditions are reasonable.

We Do Not Demand or Accept Gifts and Entertainment as Business Inducements

Employees must not demand or accept any personal benefits in connection with his/her job. However, receiving gifts and entertainment from customers, suppliers, or contractors is permissible only if it is inexpensive in value and customary in nature and is consistent with applicable laws, regulations, and sound customs of trade and only if it would not affect a particular business decision of the Topcon Group.

Any gifts or entertainment that are excessive or seem unreasonable must be refused.

We Do Not Accept Money Laundering and Participate in the Financing of Terrorism

Topcon will locate CSR activities in the center of business and work on them intentionally to build, share, and implement the sense of values and standards suitable for a global enterprise.
Topcon will, to the extent of our influence, support and implement the rules and regulations that are globally approved regarding Human Rights, Labor Standards, Environment, and/or Anti-Corruption as declared in the Global Compact.
Topcon will make a social contribution voluntarily and actively through development, production, sales, and services of useful products.
Topcon will promote environmental management by creating environmentally-conscious business processes and providing environmentally-conscious products and services.
Topcon will strive to establish CSR activities in every officer and employee’s daily work and to infiltrate and establish them within global TOPCON GROUP companies.
Topcon will acquire the understanding and confidence of all the stakeholders of Topcon Group companies by providing information actively.

Established Oct. 2008

Strengthening Global Export Control System

Exports to several countries are strictly controlled under relevant Japanese and U.S. laws. If our export control compliance were lax, this could result in situations that threaten the basis of our existence as a corporation. In the worst case, the company would be subject to penalties such as an export ban due to violations of applicable laws and regulations. For this reason, as a global company, the Topcon Group is committed to activities related to maintaining and bolstering the international system of export controls.

Conducting export control audits

We conduct an annual internal audit of all departments involved in export. Then, measures for improvement requested during the audit are discussed with departments audited for one to three months after the audit to correct nonconformities at an early stage. The following year’s audit conducts follow-up to check if such measures are carried out continuously. It also checks for missing items and inadvertent errors, such as in administration procedures in the entire process. In addition, domestic and overseas group companies are audited according to an annual plan to strengthen the global export control system.

Since FY2012, we have started field audits of overseas group companies jointly with in-house lawyers of a U.S. group company specialized in U.S. laws.

Providing export control education

We provide training sessions to raise employees’ awareness about compliance. We put some thought into training materials to make them easy to understand for employees. Furthermore, we provide mandate training for employees assigned to overseas companies to raise their awareness of their leadership role in administrating export control in a region where they will work to “enhance a global export control system.”

Developing export control specialists

To improve the expertise of employees engaged in export control, Topcon Group recommends they take a “certification exam on export control” held by the Center of Information on Security Trade Control (CISTEC).

Periodically holding compliance promotion meetings

To share information on global trends and situations of export control in Topcon Group, we periodically hold compliance promotion meetings to raise the awareness of employees within the group. To thoroughly practice export control in line with these changes, export control matters, and compliance information is shared and fed back internally.

Regions requiring special control

Topcon Group designates nine countries/areas including Iran, Iraq, Cuba, Syria, Russia, Belarus, North Korea, the Crimea Region of Ukraine and/or the regions of Ukraine referred to as the Donetsk People’s Republic (DNR) and the Luhansk People’s Republic (LNR) which are subject to special regulations under the Foreign Exchange and Foreign Trade Act of Japan and relevant U.S. laws as “regions requiring special control”(as of January 2023) and applies the most stringent procedures for screening for trade and administration.

The Topcon Group provides opportunities for capacity building and self-realization to employees with various skills and character traits to help them exercise their qualities to the fullest, placing human resources as the most valuable assets.
The Topcon Group fosters professionals and global human resources* in a planned manner.
The Topcon Group clearly defines desired employee characteristics (behavior traits and sense of values) and shares the recognition with all employees.
Each Topcon Group company develops human resource development systems and specific plans suitable for its business model and scale in accordance with the Human Resources Development Policy and communicates them to all employees for implementation.

*Global human resources:
Those who are capable of direct communication with all stakeholders in carrying out their work while sharing the Topcon Group’s management principles and accepting different cultures.

Established Apr. 2010

Topcon has established a whistleblower hotline (Topcon Whistleblower System) in accordance with the Whistleblower Protection Act, which is available to directors and employees of Topcon and our domestic group company. The contact points are offered internally and externally (the contact points are independent of the Topcon Group), and reports can be made under real names, anonymously or semi-anonymously. The system also covers reports of bribery, corruption, discrimination, human rights, and harassment.

In addition, to ensure that whistleblowers are NOT treated unfairly, Topcon has put in place thorough measures such as “confidentiality and prohibition of retaliatory actions” to protect whistleblowers. Moreover, the report's content is promptly reported to the corporate auditors, followed by the investigation results in a timely manner. Regarding significant risk issues, the responses are also reported to the Board of Directors. This system is operated to ensure that the whistleblower system functions more effectively.

The Topcon Group observes laws, guidelines, and notifications related to industrial safety and health.
1. The Topcon Group sets goals and objectives for the following items: Eradication of work-related accidents and diseases and reducing risks that induce them.
2. Maintenance and promotion of mental and physical health, allowing every employee to fully exercise their abilities.
The Topcon Group contributes to improving social safety and health management standards by actively publicizing our efforts and accomplishments for safety and health.

Established Apr. 2010

Social contribution

The Topcon Group (Topcon, Topcon Healthcare, Topcon Positioning Systems) aims to contribute to society positively. As society’s values continue diversifying, we will promote efforts to realize a sustainable society through business activities.

1. Creation of Social Value
We contribute to solving social issues and creating social value by providing original products based on technological innovations, productivity improvements based on digital transformation solutions, and innovative services. Furthermore, we aim to coexist with local communities to realize affluent lifestyles for people.

2. Creating an organization that can co-create with diverse values
We develop and strengthen human resources that enable our workers to maximize their abilities and realize change by respecting the values of each individual and fostering an organizational culture that allows for diverse and flexible work styles.

3. Respect for human rights
We respect diverse values, fundamental human rights, and individual personalities and characters in light of human dignity and realize a society free of discrimination through a deep understanding of human rights in our own company and our supply chain.

Established: March, 2023

The Topcon Group offers products and services that address societal challenges based on its basic policy for Corporate Social Responsibility (CSR). At the same time, the Group attaches great importance to communications with its diverse stakeholders and endeavors to make social contributions through its business activities.

The Group conducts checks and evaluations of the performance of its Environment, Social, and Governance (ESG) activities each fiscal year. It draws on the results of these evaluations to set goals for the actions of each stakeholder in the following fiscal year.

Regarding customer satisfaction, we focus on improving the quality of our products and services and responding promptly to customer complaints. To this end, we conduct risk analyses and strengthen our design reviews, which, in turn, contributes to compliance with development schedules and quality improvement. We also pledge to conduct fair transactions with our clients by clarifying material procurement policies. We strive to raise the satisfaction level of our employees while improving their work environment. We aim to create a comfortable, highly satisfactory workplace environment by raising awareness of safety and health and enhancing efforts such as diversity.

In addition, we are making contributions to our business partners, national and local governments, global and local communities, Non-Profit Organizations, and civic groups, primarily concerning the environment. In addition to providing environmentally conscious and resource-saving products, we also offer helpful products and services for improving medical care, health, and people's lives. In so doing, we seek to reduce our environmental footprint in our procurement, development, production, and sales processes and make the environmental contributions these stakeholders desire. We also seek to communicate with shareholders and investors by enhancing information dissemination and maintaining external evaluations.

Valuing people (Respect for human rights)

The Topcon Group (Topcon, Topcon Healthcare, Topcon Positioning Systems) has a diverse global workforce comprising individuals from various backgrounds, origins, experiences, and cultures. We profoundly respect diverse values, fundamental human rights, and the uniqueness of each person, rooted in the principles of human dignity. Our commitment is to foster a workplace where every individual is treated with respect.

We are dedicated to providing equal opportunities in both employment and business. Discrimination of any form within the workplace is strictly prohibited. We ensure that all employees, job applicants, customers, and suppliers are treated fairly and equitably, irrespective of their race, religion, gender, nationality, age, physical or mental abilities, sexual orientation, or any other personal attributes. We also uphold a solid commitment to maintaining a safe and secure work environment, including a zero-tolerance policy for workplace violence, threats, or any conduct that is abusive, intimidating, disorderly, or threatening.

Furthermore, we firmly reject the use of child labor or forced labor in any aspect of our operations.

To protect workers' rights, we consider open and direct communication between labor and management essential.

Topcon Agriculture Platform (TAP)

Topcon Agriculture Platform (TAP)

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