The Code of Ethics for Clavis Co., Ltd. (hereinafter referred to as the "Code") aims to provide Clavis employees (hereinafter referred to as "Employees") with correct decision-making and ethical judgment standards.

This Code applies to all employees belonging to Clavis Co., Ltd. (hereinafter referred to as "Company").

1. employees have pride and pride as employees of Clavis Co., Ltd., and always maintain an honest and sincere attitude.

2. employees make efforts to maintain and develop individual dignity and the company's honor with a high ethical value in the attitude of representing the company, and judge by considering the company's interests first when performing various duties.

3. employees shall comply with all laws and regulations in performing their duties and act not to violate their conscience.

employees faithfully perform their duties assigned to each member and do not take the following actions against the interests of the company.

1. Receiving rewards from stakeholders

2. Unfair participation in equity interests in trading companies

3. Lack of transparency in relationships with suppliers

4. Illegal and unjust use of company assets

5. Manipulation of document coefficients and false reporting activities

employees shall establish desirable human resources on their own in the era of internationalization, openness, informatization, and industrial advancement and make steady efforts to meet them through constant self-development.

employees shall perform their duties fairly in compliance with all relevant laws and regulations.

No executive or employee shall engage in unethical or illegal acts, such as unfair instructions, mediation, solicitation, or granting preferential treatment, which may hinder the fair performance of his/her duties or others.

employees shall endeavor to avoid acts or interests that conflict with the company's interests in performing their duties.

employees shall preferentially consider the interests of the company when the understanding between the company and the individual or department is exceeded.

No executive officer or employee shall provide money or valuables, entertainment, etc. to a person related to his/her duties that may hinder fairness beyond the scope accepted by social norms in relation to his/her duties or receive it from a person related to his/her duties.

employees clearly distinguish between public and private companies in performing their duties and do not take the following actions.

1. employees shall not cause property damage to the company by using the company's property privately or using the company's budget for other purposes.

2. employees shall not spend time on personal work during working hours to interfere with the performance of their work or use it for inappropriate purposes other than business purposes, such as online games, gambling, or visiting pornographic sites using in-house information and communication systems.

3. employees do not use their position to pursue personal interests.

1. employees shall refrain from empty formalities and make frugal food, clothing, and shelter and healthy leisure activities a daily life.

2. employees shall endeavor to establish a sound congratulatory culture, refrain from giving notifications of congratulatory events to those involved in their duties, and ensure that congratulatory gifts are not excessive in light of social norms.

1. employees shall acquire and manage all information fairly and transparently, and information such as accounting records shall be accurately and honestly recorded and managed.

2. employees shall not divulge or unfairly use job-related acquisition information to the outside without prior permission or approval from the CEO or the head of the department under his/her jurisdiction.

3. employees do not make false or exaggerated reports for the benefit of a specific individual or department and do not conceal or monopolize important information.

The company treats each employee as a dignified person with trust in employees, and respects the religious and political will and privacy of each employee.

1. employees shall observe the basic manners necessary for mutual work life and shall not engage in acts that cause distress, such as irreverent words and actions or slander other employees.

2. employees shall not create factions or treat them differently according to academic background, gender, religion, blood ties, region of origin, etc.

3. employees shall not engage in unfair solicitation, excessive gift provision, money transactions, etc. according to social norms.

4. The superior shall not give unfair instructions to the subordinate, and the subordinate shall comply with the legitimate instructions of the superior, but refuse unfair instructions.

5. employees should not engage in acts that induce sexual temptation or sexual shame.

The company gives equal opportunities according to the individual abilities and qualities of employees in education and treatment, evaluates and rewards performance and achievements fairly, and does not discriminate on the grounds of gender, education, age, religion, region of origin, and physical disability.

The company actively supports the development of employees' abilities to foster professional and creative talents, and creates conditions for all employees to freely propose and express their opinions to promote creative and autonomous thinking and behavior.

1. The company shall establish a system so that employees can perform their duties in a legitimate way and do its best to achieve pride and reward through performing their duties.

2. The company actively develops and executes programs that can create a pleasant and safe working environment for employees and improve the quality of life such as health, education, and welfare of employees and families.

The company does its best to protect the interests of shareholders through profit realization and reasonable investment.

The company guarantees equal treatment for all shareholders.

The company actively provides reliable and useful information on the company's management status and prospects to help make investment decisions and open up opportunities to participate in major decision-making.

The company records and manages its financial status in accordance with generally accepted corporate accounting standards to ensure transparent accounting.

The company strives to receive a reasonable evaluation of corporate value through active promotion and IR activities.

employees shall thoroughly protect the property of the company, and shall not engage in unfair acts such as unfair securities transactions using the company's internal information or infringement of trade secrets.

employees respect the opinions of customers in a good faith and sincerity, and make customers the priority standard for all judgments and actions of management activities.

1. employees always strive to meet the needs and expectations of customers, and provide the best services they need through innovation and creativity.

2. Provide excellent quality products and services in a timely manner, and do our best to satisfy customers through technology development and quality improvement.

3. Employees always listen and humbly accept customer opinions and suggestions, and handle customer complaints as quickly and fairly as possible.

1. Protect the customer's property and reputation without the prior approval of the customer, without divulging information related to the customer to others or using it for other purposes.

2. Information that the customer should know or should be informed to the customer should be transparently disclosed so that the customer can reasonably judge.

employees shall comply with all laws and regulations and respect domestic and foreign commerce customs in conducting all business and business activities.

Employees respect the market economy order in accordance with the principle of free competition and pursue fair competition with competitors based on mutual respect.

1. employees shall ensure that all transactions are carried out fairly in equal positions, but transparently in open and daily workplaces.

2. employees do not make unfair demands, such as demanding money and valuables, imposing unfair trading conditions, or interfering in management, using their superior position in transactions.

1. The company establishes a fair trading order through a clean and transparent trading climate with suppliers.

2. The company considers its suppliers to grow competitively in the long run and promotes joint development in accordance with the principle of reciprocity.

3. employees shall not engage in unfair activities such as cost transfer, regardless of the name of the suppliers.

1. The company respects domestic and foreign market order in accordance with the principle of free competition in the market.

2. In carrying out business activities, the company is based on mutual respect and well-meaning competition with competitors, and does not unfairly exploit competitors' weaknesses.

1. When acquiring information, employees shall use ethically appropriate channels and methods as well as related laws and regulations, and shall not acquire competitors' confidentiality illegally or unfairly.

2. employees shall not illegally or unfairly use the obtained information, such as slanderous advertisements or groundless mutual comparisons.

1. As members of the state and society, ensure sound social activities and participation of members, and faithfully fulfill the roles and duties required by society.

2. It contributes to the development of the country through job creation and sincere payment of taxes, and actively contributes to the development of social service activities and culture.

3. Efforts are made to build mutual trust with stakeholders and faithfully fulfill social responsibilities as corporate citizens.

1. The Company is not involved in politics and does not provide any professional or indirect illegal contributions or expenses to any candidate, political party, or political committee for any election position. However, it is possible to express its position on the formulation of policies or the enactment of laws related to the company's understanding.

2. We respect the personal opinions of employees, but we should be careful not to misunderstand individual opinions as the company's position, and do not allow any political activities within the company.

1. Comply with environmental-related domestic and foreign laws and international agreements, and make every effort to preserve a clean environment.

2. Try and improve to prevent any pollution that negatively affects public health and well-being.

3. Promote the use of sustainable resources by improving energy efficiency, water resource protection, and efficiency of using raw materials.

employees shall do their best to prevent disasters and risks by maintaining the cleanliness of their workplaces and complying with all laws and standards for safety.

All employees shall keep in mind that both labor and management are owners and strive for the coexistence and prosperity of labor and management based on trust and harmony.

Employees shall comply with international agreements and regulations on investment and transactions, such as the International Convention on the Prevention of Bribery in International Commerce, respect the laws and culture of the local country, and contribute to the economic development of the local country.

1. All employees pledge to be familiar with and comply with the Code of Ethics, and take responsibility for violations accordingly.

2. The CEO, executive officer, and head of each department are responsible for managing and supervising whether their employees comply with the Code of Ethics.

1. The CEO may grant personnel benefits, such as corresponding rewards, to employees who have complied with the Code of Ethics and contributed to the establishment of ethical management.

2. The CEO, executive officer, and head of each department may take necessary measures, such as disciplinary action, against employees who have committed acts in violation of the Code of Ethics.

3. The types, procedures, and effects of disciplinary action under paragraph (2) shall be governed by the company's disciplinary regulations.

These regulations shall be enacted and enforced from January 1, 2021.