CODE OF CONDUCT

The Axvircle Code of Conduct establishes fundamental principles to be observed by all employees of Axvircle Corporation (hereinafter referred to as ‘Axvircle’) in all business activities. These principles form the bedrock of our operations, guiding us to act in accordance with our corporate conscience and contribute to society.

The ‘Axvircle Code of Conduct’ is positioned as the highest internal standard for business activities and other social activities, demonstrating appropriate conduct that reflects Axvircle's corporate philosophy, applicable laws and regulations, and societal expectations.

Should a violation of the ‘Axvircle Code of Conduct’ occur, or should a potential violation be detected, prompt and appropriate corrective measures shall be taken.

The Axvircle Code of Conduct applies to Axvircle and all officers and employees working there (including directors, executive officers, advisors, consultants, employees, fixed-term employees such as contract workers, part-timers, temporary staff, seconded personnel, and agency workers).

1　Compliance

As members of the international community, we shall comply with all relevant laws and regulations required in our business activities and conduct our operations with integrity.
We shall act with integrity, maintaining the sound judgement and integrity expected of corporate professionals.

2　Social Contribution

（1）Adapting to Social Demands

As officers and employees of Axvircle, we recognize that all our business activities impact society and stakeholders. We shall act in a manner that adapts to social demands.

（2）Towards a Sustainable Society

Through our business activities, we shall consider the environmental, social, and economic impacts we create. We shall strive for a sustainable society and act based on long-term management plans.

3　Business Activities

（1）Fair Transactions

We conduct transactions fairly, based on free competition.
When selecting business partners, we consider whether they operate in accordance with this Code of Conduct, selecting them based on objective facts such as the price, quality, and delivery time of their products or services.

（2）Pursuit of Product and Service Quality

We thoroughly implement quality control and verify security risks to reliably ensure the quality and safety of the precious metal products sold by Axvircle.

（3）International Trade

We comply with the import and export laws and regulations of countries involved in international trade and prevent misconduct before it occurs.

（4）Financial Management

We pay taxes appropriately in accordance with the laws of the countries and locations where we conduct business activities. We accurately and completely record all financial information and report it within the appropriate accounting period.
We do not engage in any false recording or reporting of financial information.

（5）Non-Purchase of Conflict Minerals

When Axvircle purchases precious metal products from customers, we will not proceed with the purchase if it is determined that conflict minerals, suspected of being associated with armed groups or child labour, have been used.

(Specific Verification Procedures)

• Verify the country of origin; do not purchase if it is a conflict mineral country.
• For purchases of finished products within Japan, verification is impossible; however, the risk of conflict minerals is extremely low for finished products such as rings and necklaces. Similarly, the risk is low when the company sells legitimate products.
• When importing products from overseas (purchases from overseas account for approximately 5%), the country of origin is verified during customs clearance. The risk of conflict minerals is extremely low for finished products such as rings and necklaces. Similarly, the risk is low when the company sells legitimate products.
• For sheet materials prior to becoming finished products, the origin is verified using the supplier's delivery note based on the following criteria:
  • 

    Whether it was traded within Japan.

  • 

    Verifying the details of where it was sourced.

  • 

    For imported goods, the country of origin is confirmed; if it originates from a conflict region, we do not purchase or sell it.

（6）Money Laundering

We shall not engage in any money laundering of funds or precious metals obtained through illegal activities where the source cannot be clearly identified.

（7）Severance of Ties with Anti-Social Forces

We shall not engage in any dealings, direct or indirect, with anti-social forces or organizations that obstruct proper business activities.

（8）Bribery and Corruption

We shall not provide hospitality or gifts to customers, prospective customers, business partners, suppliers, or similar parties beyond the scope of laws, regulations, and appropriate social practices.
We shall not provide hospitality or gifts to domestic or foreign government officials, public officers, or foreign public officials beyond the scope of laws, regulations, and social practices.

（9）Conflicts of Interest

We shall act to ensure Axvircle's interests are served optimally and appropriately through our business activities.
We shall not engage in any act, or any act that may potentially lead to a conflict of interest with Axvircle.

（10）Thorough Risk Management

We shall endeavor to identify and prevent various risks within Axvircle. Should any risk materialize, we shall respond promptly.

（11）Response to Misconduct

Should we detect any unlawful acts, such as violations of laws and regulations, or any conduct suspected of being improper during our business activities, we shall promptly investigate, implement corrective measures, prevent recurrence, and deal strictly with any violations.

（12）Business Continuity

We shall implement disaster countermeasures and business continuity plans to prepare for various disasters, protect our lives, and ensure the continuity of our business.

4　Safeguarding Company Assets and Information

（1）Protection of Company Assets

We shall always be mindful of our responsibility to protect Axvircle's company assets and shall use them only for business activities with proper authorization.
We shall not use Axvircle's company assets for private purposes under any circumstances.

（2）Protection of Confidential Company Information

We shall protect all company information, including confidential information entrusted to us by customers and business partners, as well as information held by Axvircle.
We shall endeavour to prevent the loss or theft of such information and shall not disclose it without proper authorisation.

（3）Protection of Intellectual Property

We shall protect all intellectual property arising from research and development activities conducted for the purpose of Axvircle's development.
We shall not infringe upon or misuse the intellectual property of Axvircle or third parties.

（4）Protection of Personal Information

We respect the privacy of Axvircle's officers, employees, stakeholders, and all other individuals associated with Axvircle. We shall acquire personal information appropriately and use and manage it properly.
We shall establish an appropriate information security environment to prevent the leakage, loss, or damage of personal information.

（5）Appropriate Information Dissemination

When communicating internally or externally via documents, emails, etc., we shall use them following proper procedures.
We shall not disclose information concerning company operations via social networking services or similar platforms without proper authorization.

5　Respect for Human Rights

（1）Respect for Human Rights and Fair Labour Practices

We respect internationally recognized human rights and do not tolerate any human rights violations, including forced labour, racial discrimination, child labour, or harassment.

（2）Safe and Hygienic Workplace Environment

We shall thoroughly establish a safe and hygienic workplace environment to prevent accidents and illnesses in the workplace.

（3）Realizing Leisure and Well-being for Officers and Employees

We shall strive to improve working conditions collectively and realize economic, mental, and temporal leisure and well-being for officers and employees.

（4）Creating a Workplace that Utilizes Individuality and Vitality

We shall endeavor to create a rewarding workplace where every Axvircle employee can maximize their individuality, motivation, and abilities.

（5）Prohibition of Disadvantageous Treatment

We shall not subject individuals who have made sincere reports or consultations, or who have cooperated with investigations, to disadvantageous treatment or retaliatory acts on that basis.

6　Environmental Conservation

（1）Effective Utilization of Earth's Resources

In our precious metals-related business, we shall make effective use of the Earth's resources, including in the procurement of raw materials and the purchase of goods.

（2）Preservation of the Global Environment

We shall consider the preservation of the global environment, comply with environmental laws and regulations, including those concerning waste disposal, and ensure the necessary permits and licenses are obtained and appropriately renewed.
We shall contribute to reducing the environmental impact of our corporate activities and building a recycling-oriented society, striving to prevent pollution.