Our parent company, MinebeaMitsumi Inc., is committed to be not only an organization that pursues profits through

free and fair competitions  but also an entity that  broadly  provides  usefulness  to the society.  Under these circumstances,

compliance (observance of laws and ethical principles) is regarded as an important element of business management.

In addition,   our  parent  company  is  conducting  business  transactions  in a  fair  and  sincere  manner towards  its

stakeholders from the viewpoint of corporate governance. In other words,MinebeaMitsumi Inc. has duties to fulfill its social

responsibility  and  improve  its  corporate value not only by complying  with  laws and  regulations but also,  as a corporate

citizen, by conducting appropriate and fair business management based on corporate ethics.

MinebeaMitsumi Group  has upheld five rules as  basic management principles  :  "Be a company of which employees

are proud to be a part",  "Gain the trust of customers",  "Meet the expectation of shareholders",  "Be welcomed by the local

community",  and  "Contribute to the international community".  It has been clarified that an earnest and  serious attitude

toward  stakeholders  such as   shareholders,  customers,  business partners,  employees,  government  agencies,  and  the

society is a fundamental  building block of  MinebeaMitsumi business.  MinebeaMitsumi Group  has  also strived to achieve

highly transparent management.

Since the foundation in 1951,  MinebeaMitsumi Inc., has been one of the most active forerunners in promoting global

operation presence.  Through that period,  compliance with laws has been implemented as a matter of course in our group

both  domestically  and  internationally.   MinebeaMitsumi  Group’s  efforts to  promote  employment  and  foster  human

resources  have  also  contributed  to local  communities.  Furthermore,   MinebeaMitsumi  Group  have  fulfilled  a  social

responsibility  through  environmental  protection  efforts such as  obtainment of  ISO14001 for all  our  production  sites

around the world as well as through  efforts to promote labor safety  and  health in which we have obtained  ISO45001 for

factories mainly in Asia.

Consequently, our parent company has declared a commitment to continuously strive to understand corporate ethics

and  applicable laws,  harmonize with society,  and  achieve  sustained  improvement  of  corporate value  through fair and 

appropriate business management by ensuring implementation of MinebeaMitsumi Group Code of Conduct.

MinebeaMitsumi Group (Thailand),  as part of  MinebeaMitsumi  Global Group,  acknowledges and  shares  the  same

commitment. Moreover, we have a commitment to global citizenship which includes growing our company in a strong and

sustainable  way,  preserving  and  protecting  our  environment,   promoting a safe  and  healthy  work  environment  and

treating  people  with  dignity and  respect.   To put such commitment into practice, we have established and implemented

MinebeaMitsumi Group (Thailand) Code of Conduct. To ensure unity and solidarity with our parent company, our Code of

Conduct is revised to align and be in line with  MinebeaMitsumi Group Code of Conduct.

Each director and employee of our group is required to fully comprehend the purpose and comply with MinebeaMitsumi

Group (Thailand) Code of Conduct.

July 12, 2025
MinebeaMitsumi Group (Thailand)
President and Director
Yoshihiro Sakanushi

1. LABOR

The MinebeaMitsumi Group (Thailand) is committed to upholding the human rights of employees, and to treating

them  with  dignity and respect.  All companies  within MinebeaMitsumi Group (Thailand)  shall  adhere to the following

standards regarding use of labor :

(1) Freely Chosen Employment

Forced, bonded, indentured, or involuntary and inhuman prison labor shall not be used. All work shall be voluntary,

and  MinebeaMitsumi  Group (Thailand)  employees  shall  be free to leave upon reasonable  notice  in  compliance with

applicable law, regulation, and contractual agreement. MinebeaMitsumi Group (Thailand) employees shall not be required

to hand over government-issued identification, passports, or work permits as a condition of employment.

(2) No Child Labor

Child labor shall not to be used in any stage of manufacturing. The term "child" refers to any person employed under

the age of 15,  or under the age for completing compulsory education,  or under the minimum age for employment in the

country, whichever is greatest. MinebeaMitsumi Group (Thailand) supports the use of legitimate workplace apprenticeship

programs  which  comply with all laws and regulations. MinebeaMitsumi Group (Thailand) employees under the age of 18

shall not perform hazardous work and may be restricted from night work with consideration given to educational needs.

(3) Discrimination

The MinebeaMitsumi Group (Thailand) is committed to a workforce free of harassment and discrimination.Companies

within  MinebeaMitsumi Group (Thailand)  shall  not  engage  in  discrimination based on race,  color,  age,  gender,  sexual

orientation, ethnicity, disability, religion, political affiliation, union membership  or  marital status in hiring and employment

practices such as promotions, rewards, and access to training. In addition, employees or potential employees should not be

subjected to medical/pregnancy tests that could be used in a discriminatory way.

(4) Harsh or Inhumane Treatment

Companies  within  MinebeaMitsumi Group (Thailand)  shall not allow any harsh and inhumane treatment,  including

any sexual harassment,  sexual abuse, corporal punishment, mental  or  physical coercion or verbal  abuse  of  employees, 

nor shall the threat of any such treatment be allowed.

(5) Minimum Wages

Compensation paid to employees  shall  comply  with all  applicable  wage laws,  including those relating to minimum

wages, overtime hours,  and legally mandated benefits.  Any disciplinary wage deductions are to conform to applicable law

and regulation. The basis on which employees are paid shall be clearly communicated to them in a timely manner.

(6) Working Hours

Work weeks are not to exceed the maximum set by applicable  law  and  regulation.  Employees should be allowed at

least one day off per seven-day week.

(7) Freedom of Association

The MinebeaMitsumi Group (Thailand) respects the rights of its employees to associate freely, join labor unions, seek

representation, and or join workers' councils in accordance with applicable law and regulation. Employees shall be able to

communicate openly with management regarding working conditions without fear of reprisal, intimidation, or harassment.

2. HEALTH AND SAFETY

The  MinebeaMitsumi  Group (Thailand)  recognizes  that  the  quality  of  its  products  and  services, consistency of

production, and  employee  morale are enhanced by a safe and healthy work environment. All companies within Minebea

Mitsumi Group (Thailand) shall adhere to the following standards regarding health and safety :

(1) Machine Safeguarding

Physical guards, interlocks and barriers for machinery used by employees shall be provided where appropriate, and

shall be properly maintained.

(2) Industrial Hygiene

Employee exposure to chemical, biological and physical agents shall be identified, evaluated, and controlled. When

hazards cannot be adequately  controlled by engineering  and  administrative  means,  employees shall be provided with

appropriate personal protective equipment.

(3) Safety

Employee exposure to workplace safety hazards shall be identified, evaluated, and controlled through proper design,

engineering and administrative controls,  preventative maintenance,  and safe work procedures.  Where hazards cannot be

adequately controlled by these means, employees shall be provided with appropriate personal protective equipment.

(4) Emergency Preparedness and Response

Emergency  situations  and  events  shall  be  identified  and  assessed, and their impact minimized by implementing

emergency response and recovery plans and procedures.

(5) Occupational Injury and Illness

Procedures and systems shall be implemented to manage, track and report occupational injury and illness, including

provisions to :

a) encourage worker reporting;
b) classify and record injury and illness cases;
c) provide necessary medical treatment;
d) investigate cases and implement corrective actions to eliminate their causes ; and,
e) facilitate return of employees to work.

(6) Physically Demanding Work

Employee exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged

standing, and highly repetitive or forceful assembly tasks shall be identified, evaluated and controlled. Employees shall be

provided with appropriate equipment to perform such tasks.

(7) Dormitory and Canteen

Workers  shall  be  provided with clean toilet  facilities,  access to potable water and  sanitary food  preparation and

storage facilities. Worker dormitories provided by the MinebeaMitsumi Group (Thailand) shall be clean, safe,  and provide

emergency egress, adequate heat and ventilation, and reasonable personal space.

3. ENVIRONMENT

The MinebeaMitsumi Group (Thailand)  recognizes  that environmental responsibility is integral to producing world

class products.  In our operations,  adverse  effects on the  environment  and natural  resources  shall be minimized while

safeguarding the health and safety of the public.  All  companies  within  MinebeaMitsumi Group (Thailand) shall  adhere 

to  the  following standards regarding the environment :

(1) Product Content Restrictions

All  products  shall adhere to applicable laws,  regulations,  and  customer  requirements  regarding  prohibition or

restriction of specific substances, including labeling laws and regulations for recycling and disposal.

(2) Chemical and Hazardous Materials

Chemical  and  other materials posing a hazard  if released to the environment shall be identified and managed to

ensure their safe handling, movement, storage, recycling or reuse, and disposal.

(3) Wastewater and Solid Waste

Wastewater  and  solid waste generated from operations,  industrial processes,  and sanitation  facilities  shall  be

monitored, controlled, and treated as required by applicable law and regulation, and waste data shall be tracked.

(4) Air Emissions

Air emissions of volatile organic chemicals,  aerosols,  corrosives,  particulates,  ozone  depleting  chemicals  and

combustion by-products  generated  from  operations shall be characterized,  monitored,  controlled,  and  treated  as

required by applicable law and regulation.

(5) Environmental Permits and Reporting

All  environmental  permits and  registrations  required  by  applicable  law  and  regulation  shall  be  obtained,

maintained, and kept current.  The operational and reporting  requirements  of  all permits  and  registrations shall be

followed.

(6) Pollution Prevention and Resource Reduction

Waste of all types, including water and energy,  are to be reduced or eliminated to the extent practicable at the

source  or  by  practices  such as  modifying  production,  maintenance,  and facility processes,  materials substitution,

conservation, recycling, and or re-using materials.

(7) Energy Consumption and Greenhouse Gas Emissions

The MinebeaMitsumi Group (Thailand) has set targets and reports on company-wide greenhouse gas reductions.

We track and disclose energy consumption and greenhouse gas emissions for all Scopes 1, 2 and significant categories

of Scope 3  and look for and  implement ways to improve  energy  efficiency and to minimize energy consumption and

greenhouse gas emissions.

4. ETHICS AND BUSINESS PRACTICE

To meet our social responsibilities  and to increase our corporate value,  The  MinebeaMitsumi  Group (Thailand)

has to uphold the highest standards of ethics including :

(1) No Corruption, Extortion, or Embezzlement

The highest standards of integrity shall be maintained in all business interactions. Any and all forms of corruption,

extortion and embezzlement are strictly prohibited. Any such conduct may result in termination and legal action.

(2) Disclosure of Information

Information regarding business activities,  structure,  financial situation  and  performance is  to  be  disclosed in

accordance with applicable regulations and prevailing industry practices.

(3) No Improper Advantage

Bribes or other means of obtaining undue shall not be offered or accepted.

(4) Fair Business, Advertising, and Competition

Standards of fair business,  advertising,  and  competition are to be upheld.  Customer  information  shall  be

safeguarded.

(5) Community Engagement and International Operation

Community engagement is encouraged to help foster social and economic development. The MinebeaMitsumi

Group (Thailand), as an international corporation, contributes to the development of the community in every country

in which we operate by not only complying with the laws and rules of each country, but also by respecting its history,

culture and customs.

(6) Protection of Intellectual Property

The  MinebeaMitsumi Group (Thailand)  respects  intellectual property rights and  implements proper measures to

protect others' intellectual rights. To protect those rights, the Group also pays full attention to transferring and handling

our or others' technologies or know-how. 

(7) Import/Export

Compliance with not only the laws and rules of each country but also all  applicable international  rules, regulations,

and trade agreements shall be maintained when trading products or materials with, or providing technological assistance

to, foreign countries. Appropriate management systems and procedures shall be maintained to assure compliance.

(8) Response to Antisocial Forces

The MinebeaMitsumi Group (Thailand) has no relations with any antisocial forces that may or will pose a threat to

the  public order and/or safety.  At the same time,  regarding unreasonable demands,  if any, from such forces,  without

making compromises,  the  Group shall cooperate with external  specialized  institutions,  including  police  and lawyers,

and deal with such demands in a resolute attitude.

1. ROLE OF THIS CODE OF CONDUCT

This Code of Conduct is one of the important tools for practicing Compliance based on the company policy. We assure

all the stakeholders that, by  practices  based on the  system described below,  we will carefully follow the guidelines set out

in This Code of Conduct.

2. STRUCTURE OF COMPLIANCE

(1) Chief Officer of Compliance

President and Director of MinebeaMitsumi group (Thailand)  takes a role of the chief officer of the compliance system

of MinebeaMitsumi Group (Thailand).

(2) Compliance Committee

The  Compliance Committee,  a body to promote  Compliance  including this Code of Conduct,  is established directly

under President and Director of MinebeaMitsumi Group (Thailand).

The Compliance Committee assumes the operation of this Code of Conduct, approved by the Board of Directors, and

takes a role of making decisions to address urgent requirements when a serious violation of the compliance occurs.

A  secretariat for the Compliance  Committee shall be the Compliance Office.  The secretariat functions as an organ to

execute and promote compliance measures approved by the Compliance Committee. It also functions as the secretariat for

the body that makes decisions to address urgent requirements when a serious violation of the compliance occurs.

(3) Application to Each Company of MinebeaMitsumi Group (Thailand) and Supply Chain

This  Code  of  Conduct is to be  circulated to each company of  MinebeaMitsumi Group (Thailand).  Each company is

required to take necessary compliance measures in accordance with this Code of Conduct.

Moreover, efforts shall be made to voluntarily observe this Code of Conduct in the MinebeaMitsumi Group (Thailand)'s

supply chain, and each company shall request as appropriate that its suppliers and subcontractors agree to and implement

this Code of Conduct.

(4) Addition of Detailed Guidelines

When putting this Code of Conduct into practice,  while some detailed guidelines have been already stipulated,  new

detailed guidelines may be added according to specific requirements. We must comply not only with this Code of Conduct

but also with such new detailed guidelines.

(5) Duty to Report

When you are not sure if your acts or decisions violate this Code of Conduct, it is your duty to consult your superiors,

the competent departments or the consultation service separately designated by the Company.

Also, when  you notice  any violation of this Code  of  Conduct by a director or an employee,  you  must  immediately

report to the  Compliance  Office,  Human Resources and Administration Division or the consultation service designated by

the Company.

We  ensure  that  every  aspect  of  the  privacy,  such as  his/her  name  and  the  content  of  the  above-mentioned

consultation, will be kept secret. We also ensure that he/she will not be disadvantaged due to such consultation.

(6) Penalty

In case of violating this Code of Conduct,  one will be subjected to disciplinary action according to the company rules.

When  the  act of violation causes damage to the company,  he/she may be required to indemnify the company for the loss.

One who violates this Code of Conduct for the following reasons will not be exempt from responsibility :

1. 1. 1. 1. Lack of knowledge on laws and regulations.
         2. Absence of intention to violate the laws and regulations.
         3. Intention to act for the benefit of the company.
            
            

(7) Education and Training

Based  on  this  Code of Conduct, education and training concerning compliance are conducted for the following

purposes. The employees who are ordered to participate in the training by the Compliance Committee, the secretariat,

or an immediate supervisor must not refuse or fail to attend the training without legitimate reasons.

1. 1. 1. 1. To increase the awareness of overall compliance issues such as laws and regulations as well as
            corporate ethics.
         2. To provide accurate knowledge of this Code of Conduct and various office regulations.
            
            

(8) Audit

Each company of MinebeaMitsumi Group (Thailand) is required to conduct regular internal audits in accordance with

this Code of Conduct to ensure none of the company activities violates the compliance manual.

With  the  cooperation  of  each related department,  the secretariat,  according  to  the  specific  requirements,  is to

conduct audit to find out if there is any acts of violation of the compliance within our group. The secretariat is then required

to report the  result  of  the  audit  to  the  Compliance  Committee.  It  also  orders  the  concerned department/section  to 

correct its inadequate operation if necessary.

3. SUPPLEMENTARY PROVISION

(1) Revision

This  Code  of  Conduct  is  revised  when the  Board of  Directors  of  the  Company  approves  the  draft prepared by

a secretariat.

(2) Enactment and Amendment

Enactment     :   May 4, 2009
Amendment  :   June 19, 2009
Amendment  :   September 9, 2010

Amendment  :   July 13, 2012

Amendment  :   March 20, 2014 (Change the name of person-in-charge)

Amendment  :   February 1, 2016

Amendment  :   August 15, 2017

Amendment  :   April 1, 2020 (Change the name of person-in-charge)

Amendment  :   May 11, 2022 (Change the name of person-in-charge)

Amendment  :   July 12, 2025